The problem with the “substantial processing” loophole, as Insider pointed out, is that once a product is processed in another country, it can be marked as originating in the country of processing. For example, frozen fish sticks. Fish caught in Russia cannot be imported into the United States under current sanctions, however, if Russian fisheries send their pollock to a facility in China that processes it into fish sticks and packages them for sale in your section from local freezing, it is marked as an import from China, even though, as the AP reports, the pollock does not originate in China and cannot originate there.
This is exactly what Russia is doing. According to the AP report, about a third of the fish imported from China to the United States is actually caught in Russia, but American consumers and restaurateurs opposed to a war, which could cripple the world’s food supply, do not have no way of knowing because country of origin labeling is not required for imports.
Insider reports that this problem has also arisen with diamonds, although the big players in the jewelry market have been more proactive in avoiding the problem. While around 30% of the world’s diamonds come from Russia, almost all of them are cut in facilities in India and are therefore marketed as Indian products. However, buyers such as Tiffany’s and Signet – owners of jewelers Zales and Kay – began sourcing purchased diamonds from processors around the world, cutting off the Russian market.