Country of origin marking on shrink-wrapped packages of wood parquet floor tiles from Jamaica; 19 CFR 134.46; "handcrafted in" as wording similar to "made in" or "product of."

NY 892192 November 29, 1993 MAR-2-44:S:N:N8:230 892192 CATEGORY: Marking Ms. Susan C. Leavitt Halstead New England Corp. 289 Greenwich Avenue Greenwich, CT 06830 RE: Country of origin marking on shrink-wrapped packages of wood parquet floor tiles from Jamaica; 19 CFR 134.46; "handcrafted in" as wording similar to "made in" or "product of." Dear Ms. Leavitt: In your letter dated November 3, 1993, you requested a ruling on the acceptability of proposed country of origin marking on certain packaged wood parquet flooring made in Jamaica from American lumber. A sample was submitted and will be retained for reference. It consists of a stack of 10 wood parquet floor tiles (12" x 12" x 5/16") which have been shrink-wrapped, together with a paper label or "wrap card," in transparent plastic film. The "wrap card," which has been placed on top of the stack and is visible through the packaging material, is printed with product information. The lower left hand corner of the card bears a bar code, next to which appears the phrase, "Made in Jamaica by Halstead N.E. Corp, Greenwich, Ct., USA." This wording is printed in the smallest lettering appearing anywhere on the sheet. But because the words "Genuine AMERICAN Oak" also appear, in much larger lettering in two places elsewhere on the card, this country of origin marking would normally be unacceptable. In this instance, however, the phrase "Parquet Floor Tiles handcrafted in JAMAICA" also appears, in reasonably close proximity and in lettering of comparable size, to "Genuine AMERICAN Oak," in both locations, as is required in such circumstances by section 134.46 of the Customs Regulations (19 CFR 134.46). We believe that the above-described label makes it sufficiently clear that the tiles are manufactured in Jamaica, and we therefore find that it will be acceptable for country of origin marking purposes. Please note that it is assumed that the floor tiles will be sold to ultimate purchasers in labeled, shrink-wrapped packages like the submitted sample. Tiles sold by the piece would have to be individually marked. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). 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. Sincerely, Jean F. Maguire Area Director New York Seaport