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NY I84381

August 19, 2002

MAR-2 RR:NC:TA:350 I84381


Mr. Joseph Sebastian
CRP Industries Inc.
1 Minute Street
Carteret, NJ 07008-1198


Dear Mr. Sebastian:

In your letter dated July 24, 2002, with additional information that was lacking in the original request of June 24th, you requested a ruling on acceptable marking.

You requested a country of origin determination for a Tensioner Kit, which is used to service automobiles. Each engine type and model has its specific timing belt and tensioner. A tensioner is used to obtain the correct belt tautness. The kit will consist of a replacement timing belt and appropriate tensioner for specific automotive engines. You give as an example; kit TB276K1 which consists of tensioner # ZZMO-12-700 and timing belt #F57B6268A. This kit fits a 2.3 Mazda engine, year 1995-97.

You write that the synchronous timing belts are either imported from Germany or Mexico and they are not imported together with the tensioners. Further, you say that you buy the tensioners locally and do not import them, however, they are made in Korea according to the supplier’s information and declaration on their box. Your sole domestic operation is to place a specific timing belt with the appropriate tensioner into a box to make a replacement “kit.”

Your inquiry is to determine the country of origin for such a kit, which components are imported from different countries.

Repackaging does not change the country of origin of the therein contained goods, their particular origin must be known. The “kit” does not become a product of the United States. You may say “Packaged in the USA”, and, also, indicate the countries of origin of the respective components, e.g., Belt – Mexico or Germany, as marked, Tensioner – Korea. Further, we will assume that each component itself is appropriately marked with the country of origin.

It is important to note that what is NOT acceptable is to use the word “Assembled” as in Kit Assembled or Assembled in the USA (CR § 134.43).

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 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 George Barth at 646-733-3044.


Robert B. Swierupski

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