MAR-20-5 CO:R:V:C 732271 RSD
Mr. Harold Loring
Grundfeld, Desiderio, Lebowitz & Silverman
12 East 49th Street
New York, NY 10017
RE: Country of origin of marking requirements of retail containers of glass giftware
Dear Mr. Loring:
This is response to your letters of March 22, and April 4, 1989, requesting a ruling on the country of origin marking requirements of unsealed containers of imported crystal giftware. We regret the delay in responding to your inquiry.
FACTS:
Your client, Crystal Clear Industries, Inc., is an importer
of glassware products. It wants to import the glassware which will be sold in unsealed retail containers. Each piece of glassware will have a sticker on it which its country of origin. The importer does not want mark the retail boxes. Three samples: a handcut crystal rose bowl, a crystal glass picture frame, a handcrafted crystal beer mug were submitted. These articles were marked with stickers to indicate the country origin. The retail boxes, containing the samples, are unsealed but do not contain any indication of the country of origin. The boxes have fold-out tabs which allow the unsealed boxes to be opened by the retail consumer.
In your letter of April 4, 1989, you inquire if the cartons are marked "Carton Printed in Italy," whether it will trigger the requirements of 19 CFR 134.46 that the cartons also be marked with the country of origin of the glassware.
ISSUES:
Do the unsealed retail boxes containing glassware have to be marked with the country of origin if the articles themselves are marked?
Do the unsealed retail boxes