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NY 818403

January 30, 1996

MAR-2-05:RR:NC:GI:115 818403


Ms. Janet Amadeo
Airport Clearance Service, Inc.
Cargo Distribution Center
55 Inip Drive
Inwood Drive, NY 11096

RE: The country of origin marking requirements for saws from Japan.

Dear Ms. Amadeo:

In your letter dated January 4, 1996, you requested a ruling on the country of origin marking requirements for saws, on behalf of your client, Pygar Inc., Kirkland WA.

The subject item is a Felco folding miracle saw. It has a handle approximately 7" in length and a folding saw blade which is 6". The blade is made in Japan. The handle is made in China. For safety and marketing purposes, a packaging card will be sold with the Felco folding miracle saw. This card is clearly marked Japan in close proximity to the importer's address which is also clearly marked.

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.

Section 134.46 of the Customs Regulations (19 CFR 134.46) provides that in any case where the words "U.S.," "American," or any variation of such words or letters, or the name of any city or locality in the U.S., or the name of any foreign country or locality other than the country or locality in which the article was manufactured or produced, appear on any imported article or its container, there shall appear, legibly and permanently, in close proximity to such words, letters or name, and at least in a comparable size, the name of the country of origin preceded by "Made in," "Product of," or other words of similar meaning.

Your product is not legally marked as to its proper country of origin. To comply with the marking statutes, the card should be marked blade -- "Made in", Product of", or "Manufactured in" Japan. Additionally, the card should be marked handle -- "Made in", "Product of", or "Manufactured in", China. Where you now have the designation Japan on the card, would be an acceptable place to have the aforementioned marking requirements so designated.

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.


Roger J. Silvestri
Area Director

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