The country of origin marking of leather beverage cup sleeves

N362771
July 10, 2026
MAR-2:OT:RR:NC:N3: 348
CATEGORY: Marking Abraham Hernandez Abraham Hernandez DBA Abraham Hernandez 509 Idylwood Ln Laredo, TX 78045 RE: The country of origin marking of leather beverage cup sleeves Dear Mr. Hernandez: This is in response to your letter dated June 30, 2026, on behalf of Clayton & Crume, requesting a ruling on whether the proposed marking "Hecho en Mexico" is an acceptable country of origin marking for imported leather beverage cup sleeves. A marked sample was not submitted with your letter for review. The merchandise consists of genuine leather pieces that have been precut to specific geometric dimensions in Mexico. In their imported condition, these articles are cut-to-shape and dedicated for use as components of leather beverage cup sleeves. The imported pre-cut leather pieces are packed and transported in bulk industrial cardboard cartons and marked “Hecho en Mexico.” In the United States, the bulk cartons are transported to a facility for post-importation manufacturing and assembly operations that include embossing, punching and stitching/assembly. 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 United States 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 United States 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 United States 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 is not acceptable. The cardboard cartons are stamped with the country of origin in a foreign language. Section 304 requires the country of origin to be marked in English in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit. Additionally, the regulations set forth the following procedures for imported articles which will be repacked or manipulated: (a) Certification requirements. If an article subject to these requirements is intended to be repacked in retail containers (e.g., blister packs) after its release from Customs custody, or if the port director having custody of the article, has reason to believe such article will be repacked after its release, the importer shall certify to the port director that: (1) If the importer does the repacking, he shall not obscure or conceal the country of origin marking appearing on the article, or else the new container shall be marked to indicate the country of origin of the article in accordance with the requirements of this part; or (2) if the article is intended to be sold or transferred to a subsequent purchaser or repacker, the importer shall notify such purchaser or transferee, in writing, at the time of sale or transfer, that any repacking of the article must conform to these requirements … 19 C.F.R. 134.26(a). With regard to individual repackaging after importation, the importer must submit the aforementioned certification to the port at the same time that the entry summary is filed. 19 C.F.R. § 134.26(c). The form is set forth at 19 C.F.R. § 134.26(a). For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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).

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 Rosemarie Hayward at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division