The Country of Origin Marking of “Star Drops Pink Stuff Stain Remover Spray” and “The Pink Stuff Stain Remover Powder for Whites”

N352064 August 26, 2025 MAR-2:OT:RR:NC:N3:136 CATEGORY: Marking Robert Reneau Reneau Consulting 2618 San Miguel Dr., Suite 484 Newport Beach, CA 92660 RE: The Country of Origin Marking of “Star Drops Pink Stuff Stain Remover Spray” and “The Pink Stuff Stain Remover Powder for Whites” Dear Mr. Reneau: In your letter dated August 5, 2025, on behalf of your client, JMG Int LLC, you requested a ruling on whether your client’s proposed marking is an acceptable country of origin marking for imported cleaning products from the United Kingdom. The subject products are identified as “Star Drops Pink Stuff Stain Remover Spray” and “The Pink Stuff Stain Remover Powder for Whites.” You state that these products are intended for use as household and other cleaning purposes and sold in individual retail containers. You state that both products are marked with the phase: “Manufactured in the UK by Star Brands Limited, Leeds, LS15 8ZB” and a telephone number. For the “Star Drops Pink Stuff Stain Remover Spray” the country of origin phrase is followed by the phrase: “Star Brands EU C/O Allegro, Innovation Factory, Belfast BT12 7DG” and a telephone number. For the “The Pink Stuff Stain Remover Powder for Whites” the country of origin phrase is followed by the phrase “Star Brands EU, C/O WCPH B.V. Admiraal Banckertweg 12, 2315 SR, Leiden, The Netherlands” and a telephone number. 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. 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. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable. The proposed marking of the imported cleaning products, as described above, if conspicuously, legibly, and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134, is an acceptable country of origin marking for the imported “Star Drops Pink Stuff Stain Remover Spray” and “The Pink Stuff Stain Remover Powder for Whites.” The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 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, please contact National Import Specialist Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division