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NY 810010

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May 19, 1995

MAR-2 S:N:N3:117 810010

CATEGORY: MARKING

Ms. Tania H. Cudney
Columbia Ladder Inc.
111 Bruckner Blvd.
Bronx, NY 10454

RE: COUNTRY OF ORIGIN MARKING OF IMPORTED STAINLESS STEEL TUBING

Dear Ms. Cudney:

This is in response to your letter dated April 19,1995 requesting a ruling on the country of origin marking requirements for pipe, tube or pipe fittings of iron or steel. A marked sample was submitted with your letter for review.

The product to be imported is polished stainless steel tubing measuring 1 1/2" in diameter in lengths of 47 1/2", 96" and 108". Each piece of tubing will be wrapped in a polyvinyl sleeve to protect the finish. A sample of the poly-sleeve material was submitted with your ruling request. The legend "MADE IN SINGAPORE" is continuously marked on the poly-sleeve material.

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.

19 U.S.C. 1304(c)(1), requires that all pipe (iron, steel, stainless steel), tube and pipe fittings (steel, stainless steel, chrome-moly steel or cast or malleable iron) shall be marked to indicate the proper country of origin by one of five methods, die stamping, cast-in-mold lettering, etching, engraving, or continuous paint stenciling.

19 U.S.C. 1304(c)(2), provides that if, because of the nature of an article, it is technically or commercially infeasible to mark by one of the five prescribed methods, the article may be marked by an equally permanent method of marking or in the case of small diameter pipe, tube or pipe fittings, by tagging the containers or bundles.

Permissible alternative methods of marking the type of product you plan to import, ornamental pipes, tubes, and fittings of all types, having highly polished surfaces, are specified in T.D. 86-15. These alternative methods allow for marking each piece separately with a durable tag or sticker securely affixed to the article or for separately wrapping each piece in a protective wrapping which clearly indicates the country of origin.

The proposed method of marking the imported polished stainless steel tubing, by wrapping each piece in a polyvinyl sleeve which has "MADE IN SINGAPORE" continuously marked on the sleeve, satisfies the marking requirements of 19 U.S.C. 1304(c) and is an acceptable country of origin marking for the imported tubing.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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