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NY A88239

October 8, 1996

MAR-2-73:RR:NC:1:117 A88239


Mr. C. Lang
Simpson-Lawrence Engineering Limited
Hillington Road
G52 4SZ, UK


Dear Mr. Lang:

This is in response to your letter dated September 24, 1996 requesting a ruling on whether the proposed marking "UK" is an acceptable country of origin marking for imported marine anchors. A marked sample was not submitted with your letter for review.

You state that the marking "UK" is cast into the metal ballast section on the bottom of the anchor and ask whether this is acceptable as a country of origin marking for anchors produced in the United Kingdom. You also ask whether "GB" or "GBR" would be acceptable country of origin markings.

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, 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 its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article.

As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain.

With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable.

With regard to approved markings of country name, section 134.45(b), Customs Regulations (19 CFR 134.45(b)), provides that abbreviations which unmistakably indicate the name of the country, such as "Gt. Britain" for "Great Britain" is acceptable. "UK" for United Kingdom has also been found acceptable. "GB" and "GBR" do not unmistakably indicate the name of the country and therefore would not be acceptable markings.

The proposed marking of imported anchors with "UK" cast into the metal is conspicuously, legibly and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134 and is an acceptable country of origin marking for the imported anchors.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Paula Ilardi at 212-466-5476.


Roger J. Silvestri

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