MAR-2:OT:RR:NC:N1:128
Mr. Julian Inclan
The Marble & Tile Group, LLC
PMB 297
Guaynabo, PR 00969
RE: The country of origin marking of White Marble Dolomite Kyknos from Greece.
Dear Mr. Inclan:
This is in response to your letter dated January 26, 2026, requesting a ruling on whether the proposed
marking “Made in Greece” on the shipping packaging is an acceptable country of origin marking for the
imported White Marble Dolomite Kyknos. Photographs of your proposed marking were submitted in a
subsequent email.
From the information you provided, the stone is quarried, cut to size (60 centimeters long by 120 centimeters
wide by 2 centimeters thick), and surface-worked in Greece. It is then shipped to the United States in
wooden crates which are stamped with the words “Made in Greece.” You state that the White Marble
Dolomite Kyknos is not removed or repacked after importation; it is sold to retail customers in those same
marked shipping crates, ready to install, for applications such as flooring and wall coverings.
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, such as an adhesive label, is acceptable.
The proposed marking of the White Marble Dolomite Kyknos, as described above, is conspicuously, legibly
and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134
and is an acceptable country of origin marking for the imported 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 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 Nicole Sullivan at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division