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NY 897785

May 19, 1994

MAR-2-48:S:N:N8:234 897785


Mr. Dean Holbrook
Forsythe, Holbrook, Patton, Bovene, Seward & Ellis 420 Lexington Avenue
New York, N.Y. 10170

RE: The country of origin marking of previously imported pressure sensitive paper

Dear Mr. Holbrook;

This is in response to your letters of April 13, 1994, and May 3, 1994, in which you ask for a ruling concerning necessary country of origin marking for previously imported pressure sensitive paper originating abroad.

Your client, UPM-Raflatac, Inc. ("Raflatac"), a North Carolina company, imports pressure sensitive paper used for label manufacturing, in rolls 78 inches wide. The imported paper rolls arrive in containers which are marked with the contry of origin. Raflatec then custom manufactures the rolls into sections 3 to 16 inched wide and sells the cut rolls to U.S. customsers who are generally printers. The cut rolls are put on pallets, shrink wrapped, and shipped to these customers.

You request confirmation that it is not necessary for Raflatec to mark the foreign country of origin on the outside wrap when Raflatec ships the cut paper on pallets to its customers in the United States.

The Customs Service ordinarily would consider "Further manufacturing" done in the United States after a product is imported, only in the context of making a preliminary determination as to how the product must be marked at time of importation. If, as appears to be the case in the transaction you describe, the containers of the imported pressure sensitive paper are appropriately marked at the time of importation, we would normally have no further interwst in following the pressure sensitive paper through the channels of trade in this country.

Questions concerning the marking of articles made or processed in the United States are generally within the jurisdiction of the
Federal Trade Commission, and application for a decision may be
made to the agency, Attn: Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508.


Jean F. Maguire

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