Mr. Kenny Fan
Venture Global Limited
11/F Fabrico Inc., Bldg.
Kwai Chung, N.T.
Hong Kong, China 0000
RE: The country of origin marking of products from China
Dear Mr. Fan:
In your letter dated February 26, 2015, you requested a ruling for the country of origin marking of products imported from China. You state in your letter that your U.S. customer has asked you if the country of origin marking and the rating label on products made in China can be changed from “Made in China” to “Made in PRC.”
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin imported into the United States 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 United States the English name of the country of origin of the article.
Section134.46, Customs Regulations (19 CFR 134.46), provides that: In any case in which the words “United States,” or “American,” the letters “U.S.A.,” any variation of such words or letters, or the name of any city or location in the United States, or the name of any foreign country or locality other than the country or locality in which the article was manufactured or produced appear on an imported article or its container, and those words, letters or names may mislead or deceive the ultimate purchaser as to the actual country of origin of the article, there shall appear legibly and permanently in close proximity to such words, letters or name, and in at least a comparable size, the name of the country of origin preceded by “Made in,” “Product of,” or other words of similar meaning.
Customs and Border Protection has repeatedly found that the abbreviation “PRC” is not acceptable for country of origin marking purposes. See, e.g., HQ 560693 (March 6, 1998), HQ 562901 (November 6, 2003) and HQ 727372 (March 18, 1985). However, the abbreviation “P.R. China,” or “China” would be acceptable. See HQ 730578 (July 10, 1987).
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Steven Pollichino at: firstname.lastname@example.org.
Gwenn Klein Kirschner
National Commodity Specialist Division