Country of Origin Marking - Glassware; 19 CFR 134.32(d); 19 CFR 134.34; HQ 734154.

HQ 734532 December 16, 1992 MAR-2-05 CO:R:C:V 734532 NL CATEGORY: Marking Michael K. Tomenga, Esq. McKenna & Cuneo 1575 Eye Street, N.W. Washington, D.C. 20005 RE: Country of Origin Marking - Glassware; 19 CFR 134.32(d); 19 CFR 134.34; HQ 734154. Dear Mr. Tomenga: This is in response to your letter dated February 26, 1992, in which you request a ruling on behalf of your client, World Tableware International (WTI). FACTS: WTI imports glassware for sale to institutional buyers such as restaurants and clubs. The merchandise at issue includes "stemware", "barware", "serveware", and accessories made of glass. You represent that these articles are imported and sold to the institutional buyers in sealed boxes containing between one individual and three dozen items. Both the sealed boxes and the master cartons used for importation are marked with the country of origin of the contents. It is your position that as the buyers of the glassware are the ultimate purchasers of the articles within the meaning of section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), and that marking of the containers in which articles will reach the ultimate purchasers will be sufficient under 19 CFR 134.32(d) to satisfy the country of origin marking requirements. You further state that WTI occasionally finds it necessary to open the sealed boxes after importation but prior to sale in order to assemble the quantities ordered by a customer. In those circumstances, WTI will repack the odd quantities in properly marked containers in compliance with such procedures as may be required by the district director under 19 CFR 134.34. A similar pattern of importation and repackaging was the subject of a ruling issued to WTI relating to silverware under the designation HQ 734154 (August 19, 1991). In that ruling Customs approved an identical marking proposal. ISSUE: Does the marking of the glassware as proposed satisfy the requirements of 19 U.S.C. 1304 and Part 134, Customs Regulations? LAW AND ANALYSIS: In view of the parallel marking proposal previously approved for this importer with respect to silverware in HQ 734154, it is our opinion that the marking of glassware as described above is acceptable. HOLDING: Glassware, as described herein, is marked in accordance with 19 U.S.C. 1304 and Part 134, Customs Regulations when imported and delivered to institutional buyers in marked containers and master cartons, or when repacked after importation in marked containers pursuant to 19 CFR 134.34. Sincerely, John Durant Director, Commercial