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October 2024, question 61

Entry / Entry Summary · Country of origin marking

Die-cut steel scissors were bolted together and manufactured as completely finished scissors in China, fitted with rubberized non-slip grips handles in Germany, and ultimately imported into the United States. What is the correct country of origin and marking method?

  1. "Made in Beijing" printed on a hangtag.
  2. "Made in China" printed on a sticker attached to the scissors.
  3. "Made in China" die stamped into the scissors.
  4. "Made in Germany" printed on a hangtag
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CBP's answer: C. C: "Made in China" die stamped into the scissors.

The scissors are completely made, bolted together, in China, and only grips are added in Germany, so China remains the country of origin (substantial transformation is needed to change it). Scissors are on the 134.43(a) list of articles that must be marked by die stamping, cast-in-the-mold lettering, etching or similar permanent methods, so the answer is 'Made in China' die stamped (C), not a hangtag or sticker.

shall be marked legibly and conspicuously by die stamping, cast-in-the-mold lettering, etching (acid or electrolytic), engraving 19 CFR 134.43(a)
clippers, shears, scissors, safety razors 19 CFR 134.43(a)
Further work or material added to an article in another country must effect a substantial transformation 19 CFR 134.1(b)

Search for: marked by die stamping scissors

CBP's key cites: 19 CFR 134.43(a); 19 CFR 134.11; 19 CFR 134.1(b)

Question and key from CBP's October 2024 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).