The country of origin marking requirements for a no-Hub Coupling.

NY C87299 June 15, 1998 MAR-2-05:RR:NC:1:115 C87299 CATEGORY: MARKING Mr. Andreas Ritchie Panalpina 15 Century Boulevard Two Lakeview Pl., Ste. 401 Nashville, TN 37214 RE: The country of origin marking requirements for a no-Hub Coupling. Dear Mr.Ritchie: In your letter dated April 28, 1998 you requested, on behalf of your client ACD Tridon, a country of origin marking ruling. The product is a no-Hub coupling made up of parts made in the USA: a rubber ring, a metal sleeve and two metal clamps. The metal parts are sent to Mexico where the sleeve is corrugated, the clamps put into place and spot welded to the corrugated sleeve. The item is then returned to the United States for final assembly where the rubber ring is fitted. It is your position that all of the components in the no-Hub Coupling are of American origin and that the assembly process is of a minor nature and that the final product can be marked "Made in USA". Rules for determining the country of origin of a good for purposes of Annex 311 of the North American Free Trade Agreement are found in Part 102 and specifically 102.11 is: under subparagraph (1) the country in which the good is wholly obtained or produced. In your inquiry you stated that all the parts are indeed made in the USA. The no-Hub Coupling would meet the requirements of the rules of origin and can be marked "Made in the USA".I This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 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 Melvyn Birnbaum at 212-466-5487. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division