N353215

N353215 September 23, 2025 MAR-2:OT:RR:NC:N4:415 CATEGORY: Marking Donald Stein Greenberg Traurig, LLP 2101 L Street, Northwest, Suite 1000 Washington, DC 20037 RE: The marking of a plastic handle, razor blades, and styptic pencil set. Dear Mr. Stein: In your letter dated September 3, 2025, you requested a marking ruling on behalf of your client, BIC Corporation. The product under consideration is described as the “Teens Bonnie Project Razor and Styptic Pencil.” Per your submission, when sold at the retail level, it will include a plastic handle, three or seven razor blades, and a styptic stick, all packaged together. The razor blades and styptic stick are both able to be attached to the plastic handle. Further you indicate that: 1. The plastic handle will consist of the handle with a cassette attached to it, a button, and an end plug. 2. The handle, cassette, button, and end plug will all be molded in Vietnam. 3. An O-ring necessary for the assembly of the end plug will be sourced from Malaysia and shipped to Vietnam. 4. The handle components are assembled in Vietnam. 5. The end plug with the O-ring is separately assembled in Vietnam. 6. These assembled handles and end plugs will then be shipped to Italy. They are sent in separate bulk shipments. 7. In Italy, the Italian origin styptic stick is attached to the handle. 8. The completed handle with the attached styptic stick is then shipped to the United States. 9. Separately, the razor blades are sourced from Greece and shipped to the United States. 10. At its United States facility, BIC will combine the imported handles with attached styptic pencil and the razor blades into retail packages for sale to consumers. You posed two questions as part of your request: 1. 1. What is the correct country of origin for marking of the handle with the attached styptic pencil, Vietnam, Italy, or do they need to be marked separately? 2. Once the final product is completed in the United States facility, is it sufficient to mark the product as having an origin of Greece as the razor blades would provide the essential character to the set? Section 304 of the Tariff Act of 1930, as amended (19 USC 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. Congressional intent in enacting 19 USC 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the United States Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 USC 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). As to the marking of the handle with styptic pencil and the final retail product, we look to the Treasury Decision (T.D.) 91-7, published in Volume 25, Customs Bulletin and Decisions, at 6 (January 16, 1991), which addressed, among other things, the application of country of origin marking requirements to sets. It was stated therein, at 16: … in most cases, the mere inclusion of an item in a collection will not substantially transform it into an article with a new name, character or use and, therefore, each item must be separately marked with its own country of origin. (Where the marking of the container will reasonably indicate the country of origin to the ultimate purchaser, the container may be marked instead of the individual articles. See 19 USC 1304(a)(3)(D) and 19 CFR 134.32(d)). This result is consistent with the purpose of the marking statute since the ultimate purchaser’s decision as to whether to buy the set might be influenced by the country of origin of any of the items in the set, whether or not an item gives the set its essential character. As the “Teens Bonnie Project Razor and Styptic Pencil” contains parts sourced from multiple countries that are not substantially transformed in Italy, Greece, or the United States, you will need to mark the packaging to indicate each component’s specific country of origin. This would apply to the Vietnamese origin plastic handle and the styptic pencil sourced from Italy that is shipped to the United States from Italy, and the razor blades made in Greece. 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 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. 
Sincerely,
 (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division