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NY 816678




December 6, 1995
MAR-2 RR:NC:WA:341 816678

CATEGORY: MARKING

Mr. Frank T. Garcia
Director of Operations
Encore Forwarding Inc.
Building 75, Suite 248
JFK Int'l Airport
New York, N.Y. 11430

RE: THE COUNTRY OF ORIGIN MARKING OF LEATHER WALLETS

Dear Mr Garcia:

This is in response to your letter dated November 6, 1995 requesting a ruling on whether the proposed marking "Made in India" is an acceptable country of origin marking for imported leather wallets, key cases and card cases. A marked sample of a leather billfold was submitted with your letter for review. The sample is being returned to you as requested. The request is on behalf of Coach Leatherware.

The sample submitted is a leather billfold or wallet. It is bifold design and has three credit card slots on each of the left and right sides of the interior, a full card pocket is under each of the left and right credit card sections and there are two billfold sections. The lower right hand side of the interior is embossed with the "Coach" logo.

You have proposed marking the leather goods by means of an embossing with a heavy brass die. The embossed letters will be 3/32" or 6.77 points ( a point is a unit of measure equal to 1/72 " ) high. The mark will be placed 1/16" to the left of the top edge of the right full pocket which will be visible in the center stay area. The use of the heavy brass die will insure sharp lettering which will contrast well with the leather.

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 (emphasis added)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.

The proposed marking of imported wallets, key cases and card cases , 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 articles.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Kevin Gorman at 212-466-5893.

Sincerely,

Roger J. Silvestri
Director

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