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NY 850220

April 6, 1990

CLA-2-82:S:N:N1:119 850220


TARIFF NO.: 8211.94.1000

Ms. Cynthia I. Harker
Ted L. Rausch Co. of Oregon
P.O. Box 30419
Portland, OR 97230

RE: The country of origin marking of knife blades and handles from Japan and India.

Dear Ms. Harker:

In your letter dated March 5, 1990, on behalf of Kai Cutlery USA, Inc., you requested a country of origin marking ruling.

Unfinished knife blades will be imported from Japan and staghorn handles from India. The blades and handles will have no country of origin marking.

The knife blades will be polished and hollow ground and marked with the name of the importer (Kai Cutlery USA, Inc.) and a serial number. No U.S. address will be shown. The knife blades and handles will then be assembled with U.S. made brass guards and butt caps into finished sheath knives. The knives will not be marked with a country of origin.

You have furnished the following value breakdown:

Blade F.O.B. $3.89
Handle F.O.B. $5.20
Brass Guard & Butt Cap $2.01
Polishing and hollow grinding $8.00
Assembly $7.00

Based on the above information you have furnished, we agree that the finished knife does not have to be marked with the country of origin since we would consider it to be a product of the United States. We also agree that the unfinished knife blades and the staghorn handles do not have to be marked provided the outer containers in which they are imported are marked with the country of origin.
This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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