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NY A89577

November 19, 1996

CLA-2-73:RR:NC:GI:115 A89577


Mr. John Taddeo
Trans-Border Customs Services, Inc.
Cargo Building 80
Room 228, JFK International Airport
Jamaica, NY 11430

RE: The country of origin marking requirements for key fobs from China and Turkey.

Dear Mr. Taddeo:

In your letter dated November 15, 1996, you requested a tariff classification ruling, on behalf of your client, Trafalgar, Norwalk, CT.

The two subject items are described as key fobs. Each has a metal key ring or loop attached to a 3" leather fob. A 1" x 2" tag with the marking made in China is attached to each key ring. Future shipments will be from Turkey as well as China.

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.

19 CFR 134.44(c) indicates that when tags are used, they must be attached in a conspicuous place and in a manner which assures that unless deliberately removed they will remain on the article until it reaches the ultimate purchaser. Accordingly, tags may be used to indicate the country of origin of the key fobs if the requirements of 19 CFR 134.44(c) are met. Your suggested marking of made in China (or Made in Turkey) is acceptable.

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

A copy of this 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 Melvyn Birnbaum at 212-466-5487.


Roger J. Silvestri

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