THE COUNTRY OF ORIGIN MARKING OF KNIVES

NY F82572 February 2, 2000 MAR-2 RR:NC:N1:113 F82572 CATEGORY: MARKING Mr. Barnaby L. Zelman Delta Z Knives, Inc. P.O. Box 1112 Studio City, CA 91614 RE: THE COUNTRY OF ORIGIN MARKING OF KNIVES Dear Mr. Zelman: This is in response to your letter dated January 31, 2000 requesting a ruling on whether the proposed marking "Crafted in Italy" and “Crafted in Japan” is an acceptable country of origin marking for imported knives. A marked sample was not submitted with your letter for review. The merchandise consists of a variety of knives, including hunting knives, pocketknives, sporting knives, fixed blade and folding blade knives, with or without sheaths, and of various grades of steel. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 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. As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain. In HQ 732689 of December 7, 1989, Customs ruled: The word "craft" is defined in the Random House College Dictionary as "to make or manufacture an object with skill and careful attention to detail." An ultimate purchaser would therefore understand that the phrase "Crafted in" refers to where an item was made. Further, in HQ 712210 (March 20, 1980), Customs ruled that the marking "Handcrafted in Mexico" was acceptable for the purposes of 19 U.S.C. 1304. There is no discernable difference in meaning between the word "Handcrafted" and the word "Crafted" that relates to the origin of a product. Therefore, the phrase "Crafted in" is acceptable for country of origin marking. With regard to the permanency of a marking, Section 134.43(a) provides that except for goods of a NAFTA country, knives, among other articles, shall be marked legibly and conspicuously by die stamping, cast-in-the-mold lettering, etching (acid or electrolytic), engraving, or by means of metal plates which bear the prescribed marking and which are securely attached to the article in a conspicuous place by welding, screws, or rivets. The proposed marking of imported knives, as described above, is conspicuously, legibly and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134 and is an acceptable country of origin marking for the imported knives. 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 James Smyth at 212-637-7008. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division