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NY 878223




September 18, 1992

MAR-2:S:N1:234 878223

CATEGORY: MARKING

Ms. Marti Malovani
Manager, Co-Editions
Harry N. Abrams, Inc.
100 Fifth Avenue
New York, N.Y. 10011

RE: Country of origin marking of books.

Dear Ms. Malovani:

In your letter of September 2, 1992, to Mr. Carl Abramowitz of this office, you requested confirmation of advice given concerning the country of origin marking requirements for printed books imported into the United States, noting Customs Service Decision 92-14, and other relevant Regulations and Decisions.

You ask us to confirm that where the country of origin marking appears on the front or back of the title page of an imported book, the comparable size requirement of 19 CFR 134.46 is not triggered in either of the following two situations:

1) Harry N. Abrams, Inc., often co-publishes books with museums whose names include a city name, such as The Phoenix Art Museum, the Los Angeles
County Museum of Art, the Art Institute of Chicago, the Detroit Institute of the Arts. "Harry N. Abrams, Inc., Publishers," and the name of the museum appear on the title page; "Abrams" and the name of the museum appear on the spine.

2) Harry N. Abrams, Inc., distributes books for foreign publishers. "Phaidon Press Limited/Distributed in North America by Harry N. Abrams, Inc., Publishers" or some close variation appears on the title page.

You state further that in neither situation could the ultimate purchaser be misled or deceived as to the origin of the imported book. In the first situation it is clear that the name of the city is part of the museum's proper name. In the second situation the reference to North America indicates the territory in which the book is distributed.

We concur in your analysis. Assuming that the front or back of the title page is appropriately marked, pursuant to CSD 92-14 and the relevant Customs Regulations, imported books within the scope of your situations 1) and 2) above, will be considered by Customs to be legally marked, and in compliance with Section 1304, 19 U.S. Code.

The sample books which you furnished in illustration will be retained for reference.

Sincerely,

Jean F. Maguire

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