The country of origin marking of five cleaning products

N353670
October 2, 2025
MAR-2:OT:RR:NC:N3:136
CATEGORY: Marking Robert Reneau Robert Reneau 1038 Stewart Road Thomasville, GA 31792 RE: The country of origin marking of five cleaning products Dear Mr. Reneau: In your letter dated September 12, 2025, on behalf of your client, JMG Int LLC, you requested a ruling on whether your client’s proposed marking is an acceptable country of origin marking for imported cleaning products from the United Kingdom. Images of the products’ labels were submitted with your submission for review. The subject products are identified as: The Pink Stuff, The Miracle Bathroom Foam Cleaner BL686 8 The Pink Stuff, Miracle Toilet Cleaner 260369 The Pink Stuff, Window and Glass Cleaner with Rose vinegar BL752 4 The Pink Stuff, Miracle Power Foaming Toilet Cleaner CAR818 2 The Pink Stuff, The Miracle Laundry OXI Powder Stain Remover TUB688 3 These products will be used for household and other cleaning purposes and will be sold in individual retail containers. A label is affixed to each product’s container marked with the phase “Manufactured in the UK by Star Brands Limited, Leeds, LS15 8ZB” and a telephone number. This country-of-origin phrase is followed by the phrase: “Star Brands EU, c/o Allegro, Innovation Factory, Belfast, BT12 7DG and a telephone number. 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. With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134.41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. The proposed marking of the subject cleaning products, as described above, if conspicuously, legibly, and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134, is an acceptable country of origin marking for the imported goods. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Nuccio Fera at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division