OT:RR:NC:N5:116
Mr. Lucas Theo Rehaag
German American Chamber of Commerce, Inc.
120 Wall Street, 20th Floor
New York City, New York 10005
RE: The country of origin and marking requirements of pipe and tube fittings
Dear Mr. Rehaag:
In your letter dated November 14, 2025, you requested a country of origin determination for the purposes of
applicability of trade remedies, as well as a determination on marking requirements on behalf of your client,
VACOM Montana, Inc.
The products to be imported are described as flanges, rings, gaskets, and clamps that are fully machined and
finalized at the time of importation into the United States (U.S.). At that time, they are generally suitable for
use in vacuum systems and may be placed into service immediately upon importation in applications that do
not require elevated standards of cleanliness or purity. According to your submission, the products are
sourced from multiple countries, including Germany, China, Taiwan, Thailand, and India and at the time of
importation they are marked with their respective country of origin.
Your original request was for a country of origin determination after the products had undergone cleaning
processes performed in the U.S. During our subsequent correspondence, we informed you that our office can
provide a country of origin determination for a product only at the time of importation into the U.S. and you
agreed that you were seeking a determination for the products at the time of import.
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 imported into the U.S. shall be marked in a conspicuous place as
legibly, and permanently as the nature of the article (or 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.
Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements
and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates
that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain.
19 U.S.C. 1304(c)(1), requires that all pipe (iron, steel, stainless steel), tube and pipe fittings (steel, stainless
steel, chrome-moly steel or cast or malleable iron) shall be marked to indicate the proper country of origin by
one of five methods: 1) die stamping, 2) cast-in-mold lettering, 3) etching, 4) engraving, or 5) continuous
paint stenciling.
19 U.S.C. 1304(c)(2), provides that if, because of the nature of an article, it is technically or commercially
infeasible to mark by one of the five prescribed methods, the article may be marked by an equally permanent
method of marking or in the case of small diameter pipe, tube or pipe fittings, by tagging the containers or
bundles.
The photos that were submitted showed a typed piece of paper listing the part numbers with their respective
countries of origin taped on the outside of the box in which all of the various products are imported. Neither
the products themselves, nor the plastic packages in which the products are imported, however, are marked
with the country of origin. The products will need to be marked in the manner described above, i.e., on the
product itself, if feasible, or on the individual plastic bag in which the product is imported.
Because your original request was for a determination on whether the products could be marked “Made in the
U.S.A.” after cleaning processes were performed on the products in the U.S., we advise that approval of
markings of "Made in the U.S.A." is in the jurisdiction of the Federal Trade Commission and not of Customs
and Border Protection nor the National Commodity Specialist Division. In order to get approval for marking
the products "Made in the U.S.A.," after they enter the U.S. and are cleaned, you should contact the Federal
Trade Commission, Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508,
as to whether the cleaning processes performed after importation satisfy their requirements for a marking of
“Made in the U.S.A.”
Please be advised that the products in question may be subject to additional duties at the time of import,
depending on the trade remedies in effect for the country of origin of each individual product.
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 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 Angelia Amerson at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division