The country of origin marking of the outer shipping boxes for certain locksets that are packaged and shipped from China

N361513June 10, 2026MAR-2:OT:RR:NC:121
CATEGORY: MarkingGeorge Tuttle, IIITuttle Law Offices3950 Civic Center Drive, Ste 102San Rafael, CA 94903RE: The country of origin marking of the outer shipping boxes for certain locksets that are packaged andshipped from ChinaDear Mr. Tuttle, III:This is in response to your letter dated
May 13, 2026
, requesting a marking ruling on behalf of Taiwan FuHsing Industrial Co., Ltd. You have asked whether the proposed marking "Exported from China" isacceptable for the outer shipping boxes for certain locksets that are packaged in and shipped from China.Photographs and descriptions of the merchandise were included in your inquiry.This request concerns the outer shipping cartons only. The merchandise imported inside the shipping cartonsare certain locksets in which the essential operational elements are manufactured and assembled in Taiwanand then shipped to China for final assembly, packaging, and shipping. In rulings N357158 and N358850 thecountry of origin of these locksets was determined to be Taiwan. You state that both the physical locksets andthe retail packaging will be marked Made in Taiwan. These items will be packed in outer shipping cartonsthat will not be displayed to the retail consumers. You are requesting a ruling to determine if the outershipping cartons in this scenario could be marked “Exported from China.”The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unlessexcepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in aconspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) willpermit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the countryof origin of the article.As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking isconsidered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read itwithout strain. Section 134.1(d) defines the ultimate purchaser as generally the last person in the U.S. whowill receive the article in the form in which it was imported. If an imported article is to be sold at retail in itsimported form, the purchaser at retail is the ultimate purchaser.
The examples you provided describing the marking of the physical locksets and their packaging, whichwould be seen by the ultimate purchaser or consumer, as described above, are conspicuously, legibly andpermanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134 andare acceptable country of origin markings for the imported products. Therefore, the shipping or exportcartons in which the imported products are shipped to the United States do not have to be marked with acountry of origin. Based upon the facts presented, that the outer cartons do not reach the ultimate purchaserand provided that the individual products and their retail packaging are marked in accordance with Section304, the phrase “Exported from China” may be marked on the export or shipping cartons.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Jennifer Jameson at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division