RE: The country of origin marking of yoga mats

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364355 September 3, 2026 MAR-2:OT:RR:NC:N4:462 CATEGORY: Marking LoriAnn Romanowski HomeFlow Yoga LLC 2660 Kutztown Road Pennburg, PA 18073 RE: The country of origin marking of yoga mats Dear Ms. Romanowski: This is in response to your letter dated August 17, 2026, requesting a ruling on whether the proposed marking is an acceptable country of origin marking for imported yoga mats. A marked sample was not submitted with your letter for review; however, a photo was provided upon request. The products under consideration are adult yoga mats. Per your submission, each rolled yoga mat will be individually wrapped in custom-printed paper by the manufacturer in China. You state that the paper will remain wrapped around the mat until it reaches the final consumer. After importation into the US, you will place the wrapped mats in shipping cartons when fulfilling customer orders. You ask if the paper can be marked “Made in China” rather than marking the yoga mat itself, and if so, if there are any specific requirements regarding the size, placement, or permanence of the wording on the paper. The marking statute, Section 304 of the Tariff Act of 1930, as amended (19 USC 1304), provides that unless excepted, every article of foreign origin 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. Regarding the permanency of a marking, 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, 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. As provided in 19 CFR 134.41(b), the country-of-origin marking is considered conspicuous if the ultimate purchaser in the U.S. can find the marking easily and read it without strain.
A photo of the proposed country of origin marking was provided for review by this office. The photo shows white paper wrapped around the circumference of a rolled yoga mat, extending from end to end. Only the very ends of the mat remain unwrapped. The brand logo, which consists of the words “HOMEFLOW YOGA” beneath the image of an owl, is custom printed in gray font in a repeating pattern. Next to one of the logos are the words “Made in China,” in a font size, color, and placement similar to the brand logo. In HQ 733940, dated October 24, 1991, CBP described certain factors that need to be considered in determining if the country of origin marking, in that case of a pen, is conspicuous within the meaning of 19 C.F.R. 134.41 and 19 U.S.C. 1304. Among the factors that should be considered are the size of the marking, the location of the marking, whether the marking stands out, and the legibility of the marking. The clarity and size of the marking refer to how easily the ultimate purchaser can read and see the letters without difficulty or strain. The location of the marking should be in a place where the ultimate purchaser could expect to find the marking or where he/she could easily notice it from a casual inspection. Whether the marking stands out is dependent on where it appears in relationship to other print on the article and whether it is in contrasting letters to the background. No single factor should be considered conclusive by itself in determining whether a marking meets the conspicuous requirement of 19 CFR 134.41 and 19 USC 1304. Instead, it is the combination of these factors which determines whether the marking is acceptable. In some cases, a marking may be unacceptable even when it is in a large size because the letters are too hard to read or it is in a location where it would not be easily noticed. In other cases, even if the marking is small, the use of contrasting colors, which make the letters particularly stand out, could compensate to make the marking acceptable. In the instant case, while marking the outer paper wrapping rather than the yoga mat itself is acceptable, as it will remain on the yoga mat until it reaches the final customer, we find that the proposed marking, as pictured in the photo, is not acceptable as it can neither be found easily nor read without strain. The proposed marking tends to blend in with, or be camouflaged by, the repeating pattern of the brand logo. It is not in a contrasting color and does not stand out. This is known as “blind marking,” i.e., country of origin marking that is not readily visible or apparent to the ultimate purchaser. As a general rule, “blind marking” is unacceptable for country of origin purposes. Please see HQ H007453, dated February 5, 2008. The merchandise should be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit. We suggest marking in a contrasting color and in a different orientation than the repeating brand logo in order to be in compliance with the requirements of 19 USC 1304 and 19 CFR Part 134. 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 CFR 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 Sandra Walia at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division