The country of origin marking requirements for a can opener made in part in Italy and in part in China.

NY C83592 February 19, 1998 MAR-2-05:RR:NC:1:115 C83592 CATEGORY: MARKING Ms. Irene Caravas Lifetime Hoan Corporation One Merrick Avenue Westbury, New York 11590 RE: The country of origin marking requirements for a can opener made in part in Italy and in part in China. Dear Ms. Caravas: In your letter dated January 20, 1998 you requested a ruling on the country of origin marking requirements for a can opener manufactured in Italy sent to China where handles would be added. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. Section 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. Part 134, Customs Regulations (19 CFR Part 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. Section l304 Section 134.41 (b). Customs Regulations mandates that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain. In your inquiry you ask what is the country of origin after assembly and what should the markings say? The handles must be marked showing the country of origin as China. Should you continue to use the paper sleeve which states Made in Italy in close proximity to the name of the importer, then an addition must be made to the sleeve. Acceptable marking could read can opener Made in Italy, handles Made in China. The marking of the handle should not be hidden by the paper sleeve. The marking of the countries of origin on the paper sleeve must be in close proximity to the name of the importer, Lifetime Hoan Corporation. 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 Melvyn Birnbaum at 212-466-5487. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division