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NY 893657

January 26, 1994

CLA-2-S:N:N8:344 893657


Mr. Theo Kaiser
D-78056 VS-Schwenningen
Hohlehrenstrasse 27

RE: Marking Requirements on clock dials and clock cases from Germany.

Dear Mr. Kaiser:

Reference is made to your letter of December 22, 1993, wherein you inquire as to the marking requirements for clock dials and clock cases.

There are no special marking requirements for clock dials. When dials are furnished as parts of complete clocks, they are required to be visibly marked with the country of origin of the clock movement. If the clock is otherwise visibly marked to indicate the country of origin of the clock movement, there are no requirements for marking of the dial. When dials are imported separately, they require country of origin marking. This marking may be on the front or back surface of the dial. All of the above noted marking is under Section 304 and is to be of a permanent nature.

Regarding the marking of clock cases, Chapter 91 HTSUS additional U.S. Note 4.(d) requires conspicuous and indelible marking by cutting, die-sinking, engraving, stamping or mold- marking (either indented or raised, on the most visible part of the outside of the back to show the name of the country of manufacture (emphasis added). Marking of clock cases at the bottom of the base is not acceptable. This is a Special Marking Requirement of Chapter 91 HTSUS.

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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