RE: The country of origin marking of outdoor lamp kits

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 N364984 October 1, 2026 MAR-2:OT:RR:NC: 410 CATEGORY: Marking Tuan Vo Extensa Solar B.V. Brinkweg 32 Zelhem 7021 BW Netherlands RE: The country of origin marking of outdoor lamp kits Dear Mr. Vo: This is in response to your letter dated September 10, 2026. You requested a ruling on whether the proposed marking, "DESIGNED IN THE NETHERLANDS / CRAFTED IN CHINA" on the outside carton, is an acceptable country of origin marking for the imported goods. A photograph of the marked sample was submitted with your letter for review. The product is the Extensa E25 decorative cast-iron outdoor lamp kit from China. You inquire whether the individual product inside the carton may remain unmarked when the retail carton bears the proposed label. The proposal describes a 120 × 60 mm matte polyester label with permanent pressure-sensitive adhesive. It is printed with "DESIGNED IN THE NETHERLANDS" on one line and "CRAFTED IN CHINA" directly underneath. The two lines use the same font style and size. The label will be positioned clear of straps, edges, tape, and carrier labels, and will be affixed directly to the flat side panel of the carton. No separate country of origin marking is proposed for the E25 lamp kit inside the carton. The marked carton, which is tightly bound and reinforced with heavy-duty strapping bands running vertically and horizontally around the exterior, will remain intact until delivery to the ultimate U.S. purchaser. 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 imported Extensa E25 decorative cast-iron outdoor lamp kit, 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 the merchandise. 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 Michael Chen at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division