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NY 800471

August 22, 1994

MAR-2-05:S:N:N3:115 800471


Mr. Warren White
Certified Slings
P.O. Box 180127
Casselberry, FL 32718-0127

RE: The country of origin marking requirements for parts of tiedown nets from Taiwan.

Dear Mr. White:

In your letter dated July 11, 1994, you requested a ruling on the country of origin marking requirements for parts of cargo tiedown nets.
As stated in your inquiry, there are two categories of items and parts to be addressed. The first category of items is steel hardware consumed in the manufacture of cargo tiedown nets supplied under contract to the United States Air Force. The part numbers and description are as follows:

Part No. Description

64C43921 Pallet Net Hook Assembly less plates, rivets and rings
64B43920 Pallet Net Hook Plate (Ref: PN 8419-003- 67B42670-10 Hook Assembly
67C46272-10 Tensioning Hook Assembly
67B46274-01 Slide (Ref: PN PZ-0304-014)
67B46276-10 Tensioning Slide Assembly
67B46313-01 Stop Loop (Ref: PN PZ-0304-012)

All of the above imported items are subject to additional assembly work at your plant and manufactured to stringent requirements as required by the United States Government.

The second category of items are parts consumed in the manufacture of cargo control items sold commercially to other equipment manufacturers, distributors, or consumers. The imported items consist mainly of flat hooks, snap hooks, grab hooks, wire hooks, S hooks, delta rings, tensioning ratchets, cam buckles and track fittings. The products manufactured from the
imported parts include: winch strap assemblies, ratchet strap assemblies, and utility tiedown ratchets.

Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304) provides in general that any article of foreign origin (or its container) imported into the United States must be marked conspicuously, indelibly, legibly and as permanently as the nature of the article will permit in such manner as to indicate the country of origin to the ultimate purchaser in the United States.

There are general exceptions to the above marking requirements. Noting Section 134.32 of the Customs Regulations which states in part (h) articles for which the ultimate purchaser must necessarily know the country of origin by reason of the circumstances of their importation or by reason of the character of the articles even though they are not marked to indicate their origin.

This office is of the opinion that you have met the requirement setforth in Section 134.32 (h) of the Regulations for all of the items in category one listed previously and that a waiver of marking will be granted provided that the shipping containers were to be marked with the country of origin.

As to the items imported and not used in further manufacturing or assembly processes in the United States (as indicated in category two) this office rules and concurs with you that the items themselves must be marked with the country of origin along with the shipping containers.

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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