THE COUNTRY OF ORIGIN MARKING OF FOOTWEAR

N286230 June 9, 2017 MAR-2 OT:RR:NC:N3:447 CATEGORY: MARKING Mr. Greg E. Fields Vera Bradley Designs 12420 Stonebridge Road Roanoke, IN 467873 RE: THE COUNTRY OF ORIGIN MARKING OF FOOTWEAR Dear Mr. Fields: This is in response to your e-ruling letter dated May 11, 2017 in which you requested a ruling concerning the method of country of origin marking of footwear. You state that you will be importing slippers from China. You ask whether or not a sewn-in label with the country of origin in both slippers is required, or whether a label, only on the right foot slipper, would be an acceptable form of marking. In your request you also inquire whether the material content is required, and whether a hang-tag with the country of origin in lieu of a sewn-in label is an acceptable method of marking. A marked sample of the slippers, pictures, or the proposed hang-tag were not submitted for review. 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. Among the obvious locations would be on the exterior, the heel seat, or insid near the topline. In addition, when marking footwear, the country of origin must be marked on both shoes in a pair in order to ensure the marking is conspicuous. See Headquarter Ruling Letter (HRL) 731065 dated April 1, 1988; HRL 562866 dated December 8, 2003; New York Ruling Letter (NY) F84770 dated March 31, 2000; and NYRL D80525, dated August 18, 1998.  HRL 562866 also addresses when the use of hang-tags is an alternative method of marking imported footwear with the country of origin. In that ruling, CBP found that because the hang-tag at issue could not be removed, except by deliberately breaking the plastic tie, the hang-tag was sufficiently permanent to insure that the ultimate purchaser will be able to determine the country of origin. However, in order to ensure that the marking is conspicuous, the country of origin must appear on each shoe in a pair. 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 Stacey Kalkines at stacey.kalkines@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division