CBP Says 'U.A.E.' Remains Unacceptable for Marking Purposes

United Arab Emirates cannot be shortened to U.A.E. or Emirates for country of origin marking purposes, CBP said in a Feb. 28 ruling. CBP's ruling came in response to a request from Arnold & Porter lawyer Michael Shor who inquired about the marking requirements on behalf of Central National Gottesman. CBP denied the requested use of the abbreviated versions because the country is not sufficiently known under those names, the agency said.

Gottesman specifically asked CBP about the marking for copy paper from the UAE. The company asserted that "U.S. consumer awareness of the United Arab Emirates has changed in the 14 years since CBP’s last ruling with respect to this issue" and that the abbreviations are now more well known. "CBP has consistently denied a number of requests for abbreviations where it determined that the abbreviation was not sufficiently known in the United States for consumers to recognize the country of origin," the agency said.

Gottesman pointed to interchangeable usage of the shortened versions by news articles, the State Department, the CIA and CBP's own previous rulings. "We find that the interchangeable use of the 'U.A.E.' abbreviation and 'United Arab Emirates' on websites or in newspaper articles, or the occasional sole reference to 'U.A.E' or 'UAE' in such sources is not sufficient to unmistakably identify the name of the country of origin for marking purposes to the ultimate purchaser," the agency said. "Similarly, your reliance on the CIA Factbook or the U.S. Embassy websites is misplaced as we do not rely on such sources to make our determination as to recognizability of an abbreviation for country of origin marking purposes. Although the CBP rulings cited in your submission referenced 'U.A.E.,' they did not indicate that 'UAE' or 'U.A.E.' were acceptable country of origin abbreviations."