Miss Crystal Sun
Pun Chun Sauce & Preserved Fruit Fty. Ltd
362 Tan Kwai Tsuen, Hung Shui Kiu
Yuen Long, N.T., Hong Kong

RE: The country of origin marking of printed paper labels

Dear Miss Sun:

In your letter, dated February 25, 2021, you requested a binding marking ruling. A photograph was provided for our review.

The item under consideration is paper labels printed and ready for application onto soy sauce bottles. The labels are constructed of paper and are printed with product information and nutrition facts. The labels and soy sauce are of Chinese origin. The labels are clearly printed, "Made in China". In your letter, you seek to determine whether the label marking complies with U.S. regulations.

Section 134.1(b) of the Customs Regulations (19 CFR 134.1(b)) provides that the "[c]ountry of origin" means the country of manufacture, production or growth of any article of foreign origin entering the United States." Title 19 CFR 134.11 requires that every article of foreign origin (or its container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit, in such manner as to indicate to an ultimate purchaser in the United States the English name of the country of origin of the article, at the time of importation into the Customs territory of the United States.

As noted, the goods are wholly manufactured in China, and the labels are each marked "Made in China". This marking is compliant with 19 CFR 134.

US Customs and Border Protection does not govern other types of marking, such as nutrition labeling. If you are inquiring as to whether the labels comply with marking regulations other than country of origin marking, you may wish to contact the Federal Trade Commission at 600 Pennsylvania Ave., NW, Washington, DC 20580, or by phone at (202) 326-2222. Nutritional marking is governed by the US Food and Drug Administration (FDA). You may contact them at U.S. Food and Drug Administration, Center for Food Safety and Applied Nutrition, Outreach and Information Center, 5001 Campus Drive, HFS-009 College Park, MD 20740-3835. You may also reach them at 1-888-SAFEFOOD (1-888-723-3366). Electronic inquiries may be submitted at The FDA also publishes a Food Labeling Guide, which may be accessed at

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 Laurel Duvall at


Steven A. Mack
National Commodity Specialist Division