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Marking & Country of Origin

October 2021 — Question 10

An arts and crafts store will be importing a container of 150 four-hole rim buttons that are three inches in diameter and one half inch thick from France. Each button is imported in its own separate, sealed paper envelope. The store will sell the envelopes of buttons in a large bin mixed with other envelopes of buttons. Where must the importer mark the country of origin of the buttons?

Why this answer

The cited section is the J-List exception, and buttons appear on the J-List, so the buttons themselves are excepted from article marking; nothing must appear on the rim, edge, or back. The same provision instead requires that the outermost container in which a J-List article ordinarily reaches the ultimate purchaser be marked to indicate the origin of its contents. Because each button is sold to retail customers in its own sealed envelope, the envelope is that container and must show France as the origin. The display bin fails because it stays in the store; it is not what the purchaser takes away. Watch for: Marking the article itself, forgetting buttons are J-List goods whose containers carry the marking.

Original CBLE Simulator explanation — the question and key above are CBP's; this analysis is ours. Verify against the current edition before relying on it in practice.

CBP's cited authority

§ 19 CFR § 134.33

Answer and citations as published in CBP's official answer key for the October 2021 examination.

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