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NY 801482

September 23, 1994

MAR-2-90:S:N:N3:119 801482


Mr. Rick E. Peters
Active Ankle Systems Inc.
451 Baxter Avenue
Louisville, KY 40204

RE: Country of Origin Marking of Imported Strap

Dear Mr. Peters:

This is in response to your letters dated June 8 and August 17, 1994 requesting a ruling on the country of origin marking requirements for an imported strap assembled from U.S. components in Mexico. A sample was subsequently submitted to this office.

The strap is not sold alone but as a component of a U.S. made ankle brace which has rigid parts that restrict lateral motion of the ankle joint. The strap is 16 inches long, 3 inches wide and is made of webbing and Velcro material. It has a snap fastener projection on one side which presumably will be snapped into the ankle brace. You state that the cost of the complete brace is $7.50 while the cost of the strap alone is approximately $1.00.

You have requested that you be allowed to import the strap without a country of origin marking. You state that a marking such as "Assembled in Mexico" on the strap would give the impression that the complete brace is assembled in Mexico.

The marking regulations require that every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit, in such manner as to indicate to an ultimate purchaser in the U.S. the English name of the country of origin of the article.

Since the strap to be imported is a finished article which will not undergo any further manufacturing in the U.S., the country of origin marking remains a requirement. However since the strap is to be repacked after importation with the ankle brace, the certification procedures of Section 134.26 of the Customs Regulations will have to be followed. A request for a waiver of the marking on the imported article should be submitted to the Import Specialist at the port through which you plan to import the merchandise. A sample of the marking to be used on the individual containers ( e.g. "Brace made in U.S.A. - Strap assembled in Mexico) should also be submitted at the port for approval.

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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