THE COUNTRY OF ORIGIN MARKING OF DENTAL FORCEPS

N172637 July 6, 2011 MAR-2 OT:RR:NC:N4:405 CATEGORY: MARKING Thomas Haug Geomed Medizin-Technik GmbH & Co. KG Ludwigstaler Strasse 27 D-78532 Tuttlingen Germany RE: THE COUNTRY OF ORIGIN MARKING OF DENTAL FORCEPS Dear Mr. Haug: This is in response to your letter dated June 8, 2011, requesting a ruling regarding the country of origin marking for imported dental forceps. The finished forceps will be exported from Indonesia. You state that the forgings which they will be made from are entirely the product of the United States and that the forgings have been shaped in the United States with the “knurling patterns and beak geometry” that is characteristic of each individual model. We agree that the country of origin for marking purposes of the finished forceps is the United States, consistent with previous Headquarters Ruling Letters (HRLs). Particularly applicable are two of the rulings which you cite, HRL 561498, dated March 22, 2000, and HRL 561661, dated July 20, 2000. Therefore, as indicated in those rulings, since the country of origin of the finished forceps is the United States, no country of origin marking is required by 19 USC 1304. In the terms of Customs Regulation 134.11, the imports will not be articles “of foreign origin” for which there are affirmative country of origin marking requirements. We agree that whether or not any marking denoting USA origin for the imports can be present, if you wish to do so, must be decided by the Federal Trade Commission. 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 J. Sheridan at (646) 733-3012. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division