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NY A88134

October 15, 1996

MAR-2-05:RR:NC:1:115 A88134


Mr. Eduardo L. Acosta
R.L. Jones
Customhouse Brokers, Inc.
P.O. Box 472
Calexico, California 92231

RE: The NAFTA country of origin marking requirements for garden tools.

Dear Mr. Acosta:

In your letter dated September 27, 1996, you requested a ruling on the country of origin marking requirements for garden tools, on behalf of your client, Rockwood Ortega Co.

Currently the garden tool is cast in the United States, sent to Mexico for polishing and returned to the United States where a grip is placed on the tool and then packaged for retail. In the instance described, the marking of the tool can be "Made in the U.S.A.", as no substantial transformation occurred due to the simple assembly of polishing. The NAFTA marking regulations would be satisfied under Section 102.11 General Rules as found in TD 94.4.

Part 134 Country of Origin marking concerning "assembled articles" has been addressed in the Federal Register Vol 61 No. 110 dated June 6, 1996 {pertaining to NAFTA Marking rules} to cover your proposed change in procedure, whereby the U.S. made steel sent to Mexico for polishing the handle or grip added and sold for retail.

Section 134.43 Methods of marking specific articles: (e) Assembled articles --- where an article is produced as a result of an assembly operation and the country of origin of such article is determined under this chapter to be the country in which the article was finally assembled, such article may be marked, as appropriate, in a manner such as the following:

(1) Assembled in (Country of final assembly) (2) Assembled in (Country of final assembly) from components of (name of country or countries of origin of all components); or (3) Made in, or product of (Country of final assembly)

This ruling is being issued under the provisions of Section 181 of the Customs Regulations (19 C.F.R. 181).

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

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