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NY 805784




Feb. 13, 1995

CLA-2-61:S:N:N5:361 805784

CATEGORY: MARKING

Mr. Harold Loring
Grunfeld, Desiderio, Lebowitz & Silverman 245 Park Avenue
New York, N. Y. 10167

RE: The country of origin of woman's woven pants and blouse made in the Maldives and Sri Lanka.

Dear Mr. Loring:

In your letter dated January 12, 1995, on behalf of Mast Industries, Inc. you requested a country of origin determination for a pair of woman's woven pants and blouse.

The pants feature a zipper fly-front opening, a partially elasticized waistband with belt loops and two side slash pockets. The blouse features a full front opening with an 8 button right over left closure, a collar, short sleeves, two breast pockets, a back yoke, and shoulder pads.

The garments will be manufactured in the both the Maldives and Sri Lanka. Both garments will be cut into component parts in the Maldives, and sewn into the completed garments in Sri Lanka. The bolts of cloth from which the pattern parts are cut will not be marked with the pattern prior to importation in the Maldives. The parts will be sewn together and the garments finished in Sri Lanka.

For the pants, cutting the fabric to pattern is a substantial transformation, changing fabric into garment parts. The simple attaching of those parts is not considered a substantial transformation, therefore, the country of origin of the pants is the Maldives.

The blouse, however, is a tailored garment. Cutting the fabric to pattern is a substantial transformation, changing fabric into garment parts. However, the assembly of the garment is more than the simple attachment of parts, but involves more complex processes. These complex processes that create a woman's tailored blouse constitute a substantial transformation. 19 CFR 12.130(b) provides that an item will be considered a product of the country where it last underwent a substantial transformation. Therefore, the country of origin of the blouse is Sri Lanka.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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