HQ 113585 - Vessel Repair; Application for relief; S/S ARCO JUNEAU, Voyage CF491; Entry No. C31-0015284-3; Modifications; Inspection; Cleaning; Parts; Anchor chain; Texaco Marine Services, Inc. v. United States; T.D. 44359; T.D. 44886; T.D. 44913; T.D. 45453; 19 CFR 4.14; 19 U.S.C. 1466; 19 U.S.C. 1466(h)(3) - United States International Trade Commision Rulings

United States International Trade Commision Rulings And Harmonized Tariff Schedule

faqs.org Rulings By Number Rulings By Category Tariff Numbers

faqs.org > Rulings and Tariffs Home > Rulings By Number > 1996 HQ Rulings > HQ 113366 - HQ 225206 > HQ 113585

Previous Ruling Next Ruling
HQ 113585

June 6, 1996

VES-13-18-RR:IT:EC 113585 PH

CATEGORY: CARRIER

Chief, Liquidation Section
U. S. Customs Service
P. O. Box 2450
San Francisco, California 94126

RE: Vessel Repair; Application for relief; S/S ARCO JUNEAU, Voyage CF491; Entry No. C31-0015284-3; Modifications; Inspection; Cleaning; Parts; Anchor chain; Texaco Marine Services, Inc. v. United States; T.D. 44359; T.D. 44886; T.D. 44913; T.D. 45453; 19 CFR 4.14; 19 U.S.C. 1466; 19 U.S.C. 1466(h)(3)

Dear Sir:

This letter is in response to your memorandum dated September 14, 1995, which forwarded for our review an application for relief from duties relating to the above-referenced vessel repair entry. Our ruling follows.

FACTS:

The vessel ARCO JUNEAU, a United States-flag vessel owned by Metaric Corporation and operated by Arco Marine, Inc., arrived at the port of Valdez, Alaska, on April 12, 1995. A vessel repair entry was timely filed (April 12, 1995, according to Customs records). According to the vessel repair entry and other documents in the file, the vessel underwent certain work at the Hyundai Mipo Shipyard in Ulsan, Korea.

On July 10, 1995, the vessel operator submitted an application for relief from duty (dated June 29, 1995) for certain items of the work done abroad. You request us to review certain items in the entry and provide you with our determination as to the dutiability of those items. Those items, with descriptions and other information from the invoice and other materials in the file, are listed below:

Item no. Invoice description, etc.

002 Services and Facilities. This item consists of expenses related to a Gas free certificate, expenses related to docking and shifting the vessel, facilities (shore power, shore steam, fresh water, compressed air, fire main, refrigeration, fire watches, air conditioning units cooling water, communications, garbage and trash removal, crane services, stores, heat lamps or straps, protective covers (for bridge electronic equipment) (conceded to be dutiable), covering passageways and furniture (conceded to be dutiable), security guard services, and furnishing a portable generator), engine room and pump room bilge cleaning, and transportation.

108 Rudder. The portions of this item in controversy are stated to consist of the modification of the rudder by removing the side shell plating from both sides of the rudder, machining the area of the forging which supports the pintle pin, and welding in a new section of plate with improved geometry. A drawing, with an approval letter from the Coast Guard, is submitted in regard to this item. According to the invoice for this item, the work included "[g]ouged up and welded on crack area" and "[d]ismantled rudder and laid down to dock bottom for repair in sert plate as necessary". Staging is included in this item, and the cost of the staging is segregated from other costs. The cost of inspection relating to this item is also segregated. The part of the ABS survey (No. UL 5475 I) appearing to relate to this item is not included in the file (i.e., the "Summary Report of Class Surveys" refers to a number of suffixes and states that the total pages
(including checksheets) is 44, but the checksheet for this item is not included in the file).

329 Engine room bilge. This item is stated to consist of the permanent mounting of two 100 gallon vertical FRP storage tanks in addition to the two existing tanks. The item includes the fabrication and installation of straps and angle iron support, fabrication of foundation, fabrication of new piping, hose and tubing, and hydro testing upon completion of installation. According to the application for relief, the additional tanks allow for storage of bilge water when the vessel is in restricted waters.

330 Machinery space clean drain overboard pumping system. This item is stated to consist of installing owner-furnished piping from discharge of existing overboard pump to existing fitting installed in overboard piping for the fire pump. According to the application, this system permits the pumping directly overboard of clean water, rather than allowing it to drain to the bilge where it must be processed through the oil/water strainer.

401 IGS inspection and repairs. The portion of this item in controversy is stated to consist of installing level alarm sensors and two stainless steel bosses on the deck steel "U-lopp" cover for the installation of the level alarms, as well as the installation of pipe conduit and mounting brackets, and armored cable. According to the application, the purpose of this item was to allow monitoring the water seal level, which results in a higher level of safety.

403 IGS piping inspection and repairs. The portion of this item in controversy is stated to consist of disconnecting one 20 inch blind flange on the forward end of the IGS main, providing adequate ventilation, furnishing labor to crawl inside the pipe, inspecting and cleaning the interior of the IGS main deck 20 inch line, 500 feet long, and removing approximately one ton of deposit (there is a notation in the invoice indicating that the total deposit removed was 3 tons). Temporary ventilation costs are segregated in this item. According to the application, this cleaning was not in preparation for coating, it consisted of cleaning and inspection only.

414 Fire station No. 5. This item is stated to consist of releasing four angle iron supports for the fire station hose rack, moving the hose rack forward 10 feet, reattaching the angle iron supports to the deck, grinding the locations affected, and touch-up painting. According to the application, this work involved permanent welding. The reason given for the relocation was to make the hose rack more accessible (previously, personnel had to climb over pipe lines while avoiding cross braces of the accommodation ladder storage rack).

415 Fire station No. 6. This item is stated to consist of the installation of straight run piping with one flanged offsticker, fitting flanged fire station hydrants at both ends of crossover, and attaching a new section of piping to the existing offsticker on the 10 inch fire main. After welding, the fabrication of the piping section was to be hot-dip galvanized. The item included the fabrication and installation of piping brackets. According to the application, this work was to allow for laying out fire hoses at the port and starboard manifold while the vessel is engaged in cargo operations.

419 Pump room access platform. This item is stated to consist of extending the existing walkway approximately four feet toward the centerline of the vessel. Involved in the item is the installation of an angle support and handrail, cutting part of the edge of the existing walkway, welding the new platform deck to existing walkway, and coating welded fabrication and deck plating. According to the application, the reason for this extension of the ladder platform was to allow the sensor for the combustible gas detector to be serviced (previously no access to the sensor was readily available).

420 King posts, radar mast, foremast, and IGS mast riser. The portion of this item in controversy (C., Forward mast) is stated to consist of the installation of one padeye at the top of the forward mast. Staging costs are segregated in this item. According to the application, this padeye was installed for the hook-up of a personnel safety line for people going aloft for the purpose of maintaining the whistle and flood lights.

425 Rigging cleats. This item is stated to consist of installing four owner-furnished deck cleats at locations on the top of the forward breakwater, and touching up of the welded attachments. According to the application, the purpose of the addition of the cleats was to allow for safer handling of the booms during the setup period (when rigging the booms for handling hoses).

605 Room heaters. This item is stated to consist of the installation of owner-furnished steam heaters in oiler #1 staterooms. The item includes removal of overhauled panels in each stateroom and one panel in each water closet space, insulation of tubing, and installation of stainless steel sheet metal covers over lines mounted on bulkheads and new entrance door hold-back hooks and cushions in way of the new tubing runs. According to the application, the existing forced air heating system which provided heat to these rooms was insufficient to meet heating requirements. The steam heating system was changed to incorporate steam heaters in these rooms.

901 Vapor recovery system. This item is stated to consist of modifying the existing inert gas system to include a vapor recovery manifold. According to the application, under the new system, "[a]s the vessel loads cargo the vapors will collect in the shipboard piping system and will flow through a dedicated manifold connection to a shoreside facility where the vapors will be incinerated." This "is soon to be a requirement at the Valdez Marine Terminal for all tank vessels loading out of the port of Valdez, and is a requirement at Pacific Coast ports such as San Francisco and Long Beach."

Cheung Hae Slop removal. This item is stated to consist 03/15/95 of the receipt and disposal of slop wash Invoice water, sludge removal and disposal, and mucking out from No. 5 cargo tank center and starboard slop tank.

Halla Marine Anchor chain. This item is for the cost of 03/13/95 anchor chain. In the file is a copy of an Invoice Entry Summary Continuation sheet for "stud link chain" and "chain & parts, other parts", with an invoice and entry value the same as the value of the anchor chain listed in the referenced invoice.

ISSUES:

Whether the work described in the FACTS portion of this ruling is dutiable under the vessel repair statute (19 U.S.C. 1466).

LAW AND ANALYSIS:

Initially we note that the vessel repair entry and the application for relief in this matter were timely filed (see 19

Under 19 U.S.C. 1466:

The equipments, or any part thereof ... purchased for, or the repair parts or materials to be used, or the expenses of repairs made in a foreign country upon a vessel documented under the laws of the United States to engage in the foreign or coasting trade, or a vessel intended to be employed in such trade, shall, on the first arrival of such vessel in any port of the United States, be liable to entry and the payment of an ad valorem duty of 50 per centum on the cost thereof in such foreign country. ...

Section 1466 also provides, generally, for remission or refund of such duties if it is established that the purchases or repairs were compelled by stress of weather or other casualty, that the equipments or repairs were manufactured or produced in the United States and the labor necessary to install them or make the repairs was performed by United States residents or members of the regular crew of the vessel, or that the equipments or materials or labor were used as dunnage for cargo, or similar purposes. In addition, section 1466 provides for the exemption from vessel repair duties for certain materials with respect to a vessel which arrives in a United States port two years or more after its last departure from a United States port, and for certain materials for LASH (Lighter Aboard Ship) barges, or certain spare parts or materials subject to various specified conditions. The Customs Regulations issued under section 1466 are found in 19 CFR 4.14.

The Customs Service has issued many rulings applying and interpreting 19 U.S.C. 1466. See, e.g., ruling 112851, dated March 22, 1996, copy enclosed. Ruling 112851, describes the general rules for the determination of what are modifications to the hull and fittings of a vessel (held not to be dutiable under section 1466). Generally, qualifying modifications to the hull and fittings of a vessel involve a permanent incorporation into the hull or superstructure of a vessel, provide an improvement or enhancement in operation or efficiency of the vessel, and may not involve the replacement of a current part, fitting, or structure which is not in good working order. The LAW AND ANALYSIS portion of ruling HQ 112851 is incorporated by reference into this ruling, in regard to its description of the interpretation of this issue.

Insofar as cleaning operations are concerned, Customs has held that cleaning operations which remove rust and deterioration or worn parts, and which are a necessary factor in the effective restoration of a vessel to its former state of preservation, constitute vessel repairs. Analogous to Customs position regarding the dutiability of surveys (described in ruling 112851, referred to above), Customs has long held that the cost of cleaning is not dutiable unless it is performed as part of, in preparation for, or in conjunction with dutiable repairs or is an integral part of the overall maintenance of the vessel (see C.I.E.'s 18/48; 125/48; 910/59; 820/60; 51/61; 569/62; and 698/62).

Insofar as the applicability of 19 U.S.C. 1466(h)(3) is concerned (subsection 1466(h) expired on December 31, 1992, and again became effective on January 1, 1995, and so is applicable to the entry under consideration), that provision provides that duties imposed by subsection 1466(a) shall not apply to "the cost of spare parts necessarily installed before the first entry into the United States, but only if duty is paid under appropriate commodity classifications of the Harmonized Tariff Schedule of the United States [HTSUS] upon first entry into the United States of each such spare part purchased in, or imported from, a foreign country." In a memorandum of May 31, 1995 (File: VES-13-R:IT:C 113291), Customs stated that for treatment under this provision Customs would require a vessel operator to complete continuation sheets normally submitted with entries for consumption and attach them to the vessel entry form. Also according to this memorandum, Customs stated it would "... apply the provision to all parts [but not, obviously, to materials or equipments] which are purchased and installed abroad."

The recent Court decision in Texaco Marine Services, Inc. v. United States, 44 F. 3d 1539 (Fed. Cir. 1994), is applicable in this case (see memorandum dated March 3, 1995, from the Assistant Commissioner of Customs, Office of Regulations and Rulings and published in the Customs Bulletin of April 5, 1995 (Customs Bulletin and Decisions, vol. 29, no. 14, page 24), in which Customs took the position that the decision in that case was applicable, in its full weight and effect, to all vessel repair entries filed with Customs on or after the date of that decision (December 29, 1994)). Customs has considered the effect of Texaco in several rulings (see, e.g., ruling 226485, dated February 5, 1996). In ruling 226485, we noted, basically, that the Court upheld the "but for" test which had been proffered by Customs in the lower court trial (i.e., the costs involved (post- repair cleaning and protective coverings) were an integral part of the dutiable repair process and would not have been necessary "but for" the dutiable repairs). We noted that the Court provided clear guidance with respect to the proper interpretation of 19 U.S.C. 1466, in that it rejected Customs Court and CIT cases as incorrectly decided if they were inconsistent with the "but for" test (see American Viking Corp. v. United States, 37 Cust. Ct. 237, C.D. 1830, 150 F. Supp. 746 (1956) (expense of providing lighting for dutiable repairs); International Navigation Co. v. United States, 38 Cust. Ct. 5, C.D. 1836, 148 F. Supp. 448 (1957) (transportation expenses for foreign repair crew to travel to and from an anchored vessel being repaired); and Mount Washington Tanker Co. v. United States, 1 CIT 32, 505 F. Supp. 209 (1980) (transportation costs for members of a foreign repair crew performing dutiable repairs)) and explained how the case of United States v. George Hall Coal Co., 142 F. 1039 (2d Cir. 1906) (see also T.D. 24932 and 134 F. 1003 (1905)), was consistent with the "but for" test in that the expenses there were dry-docking expenses which "would have been incurred irrespective of whether or not dutiable repairs were performed" (44 F. 3d at 1546).

As we noted in ruling 226485, the decision in Texaco is dispositive of many vessel repair issues (in that it changes Customs interpretations of 19 U.S.C. in regard to a "myriad of foreign repair expenses." In a memorandum dated January 18, 1995, the Assistant Commissioner of Customs, Office of Regulations and Rulings, described some of these changes (this memorandum, published in the Customs Bulletin of February 8, 1995 (Customs Bulletin and Decisions, vol. 29, no. 6, page 59) was modified in other respects by the March 3, 1995, memorandum from the Assistant Commissioner (see above)). According to the January 18, 1995, memorandum:

... [W]e currently do not consider the following foreign costs dutiable under the vessel repair statute: air, crane, drydocking charges, electricity, travel/transportation, launch use, lodging, security and staging. Absent these costs being incurred pursuant to events such as a regularly scheduled survey or in conjunction with work that would otherwise be nondutiable or remissible (e.g., a modification or casualty), they would undoubtedly constitute [dutiable] "expenses of repairs" under the "but for" test discussed above. * * * We emphasize that this list is not all inclusive; other foreign costs not herein discussed should undergo the same scrutiny [i.e., scrutiny to ensure consistency with the "but for" test].

The LAW AND ANALYSIS portion of ruling HQ 226485, and the above-referenced January 18 and March 3, 1995, memorandums from the Assistant Commissioner (a copy of each is enclosed for your convenience) are incorporated by reference into this ruling, in regard to their description and interpretation of this issue (i.e., the applicability of Texaco).

The applicant claims that items 108 (portions only), 329, 330, 401 (portions only), 414, 415, 419, 420 (portions only), 425, 605, and 901 are non-dutiable, as modifications to the hull and fittings of the vessel. Item 108 is dutiable because the invoice refers to work which appears to be repairs (i.e., as noted in the FACTS portion of this ruling, the work included "[g]ouged up and welded on crack area" and "[d]ismantled rudder and laid down to dock bottom for repair in sert plate as necessary"). In the absence of evidence to the contrary (e.g., the specific part of the ABS survey, referred to in the FACTS portion of this ruling, could possibly establish that there were no repairs involved in this work, but that part of the ABS survey is not included in the file). We note that in ruling 110639 (invoice item 108 D), similar work was held to be non-dutiable as a modification, but in that case there was no evidence of dutiable repairs. Of course, under the "but for" test in Texaco, as described above, the costs for staging and inspection associated with this item, even though segregated, would be dutiable.

Item 329 is non-dutiable, as the permanent mounting of two FRP storage tanks in addition to the two existing tanks (see United States v. Admiral Oriental Line et al., 18 CCPA 137, T.D. 44359 (1930) (installation of a steel swimming tank held not to a dutiable repair under 19 U.S.C. 1466); and Admiral Oriental Line v. United States, T.D. 45453 (1932) (enlarging of steel emergency generator house in order to house additional machinery held not to be dutiable under section 1466 as an addition to the hull and fittings of the vessel)). We note that there is no evidence that the existing tanks were defective or in need of repair or replacement and we note that the new tanks were installed in addition to the existing tanks (see discussion of modifications in ruling HQ 112851 - qualifying modifications may not involve the replacement of a current part, fitting, or structure which is not in good working order).

Item 330 is non-dutiable, as the permanent installation of piping between the existing overboard pump to the existing overboard piping for the fire pump (see Admiral Oriental Line v. United States, T.D. 45453 (1932) (installation of a new independent filling line to the fresh-water tank, necessary because water obtained at a named port was satisfactory for boiler purposes but not for drinking purposes so that a separate and independent filling line was necessary, held not to be dutiable under 19 U.S.C. 1466 as an addition to the hull and fittings of the vessel). We note that there is no evidence that the work was to replace defective piping and we note that the new piping added a new feature (permitting the pumping of clean water directly overboard).

The portion of item 401 in controversy (installation of level alarms) is non-dutiable as an addition to the hull and fittings (see ruling 112972, January 4, 1994, invoice item 904 (installation of a new gas detection sensor in pump room and a monitor in engine room console held non-dutiable on the same basis)).

Item 414 (disconnection and reattachment at a new location of the fire station hose rack) is non-dutiable as an alteration to the hull and fittings (see ruling 112972, invoice item 513 (disconnection and relocation of ballaster for flood lights held non-dutiable on the same basis)).

Item 415 (installation of piping between fire station hydrants and offsticker) is non-dutiable as an addition to the hull and fittings on the same basis as item 330 above.

Item 419 (extension of the existing pump room access platform) is non-dutiable as a modification or alteration to the hull and fittings of the vessel (see above, see also ruling 112641, March 21, 1996, invoice items 427 (enlarging of life raft platform held non-dutiable) and 429 (extension of catwalk held non-dutiable)).

The portion of item 420 in controversy (installation of a padeye at the top of the forward mast) is non-dutiable as an addition to the hull and fittings of the vessel (see ruling 112553, February 16, 1993, invoice item 426, in which installation of bracket with pad eye to kingposts was held non-dutiable on this basis).

Item 425 (installation of rigging cleats) is non-dutiable as an addition to the hull and fittings (see Abstract 18861 (1932 protest decision of the 3rd Division of the Customs Court, Admiral Oriental Line) holding that installation of teakwood hand rails was a non-dutiable addition to the hull and fittings); C.I.E. 1294/58 (installation of "MacGregor" hatches held non-dutiable on this basis); and ruling 112454, March 31, 1993, invoice item 514 (installation of pad-eyes held non-dutiable on this basis)).

Item 605 (installation of steam heaters in staterooms) is non-dutiable as an alteration or modification to the hull and fittings (see E.E. Kelly & Co. v. United States, T.D. 44913 (1931) (permanent installation of lavatory and deck-chair compartments for storing deck chairs held to be non-dutiable on this basis), and Admiral Oriental Line v. United States, T.D. 44886 (1931) (installation of heating coils in the deep tanks of vessels held to be non-dutiable on this basis)).

Item 901 (installation of a vapor recovery manifold system) is nondutiable as an addition to the hull and fittings of the vessel (see ruling 112553, invoice item 912-6, in which the installation of a vapor recovery manifold was held non-dutiable on this basis).

The applicant claims that the portion in controversy in item 403 (disconnecting one end of the IGS main, providing ventilation, and crawling inside pipe to inspect and clean the interior and remove deposits) and the work described in the Cheung Hae 03/15/95 invoice (slop removal) are non-dutiable as consisting of cleaning and inspection only. As stated above, Customs has long held that the cost of cleaning is not dutiable unless it is performed as part of, in preparation for, or in conjunction with dutiable repairs or is an integral part of the overall maintenance of the vessel (see, in addition to the C.I.E.'s cited above for this proposition, ruling 111730, September 19, 1991, and American Mail Line, Ltd. v. United States, 35 Cust. Ct. 142, C.D. 1735 (1955) (sweeping and cleaning the holds of a vessel held non-dutiable); and Northern Steamship Co., Inc. v. United States, 54 Cust. Ct. 92, C.D. 2514 (1965) (scraping and cleaning grain, dirt, and other material (including, but only incidentally, rust) from the Rose Boxes (iron boxes containing perforations and fitted at the end of bilge suctions in order to prevent the pipes from being obstructed with solid matter) and removal of the material held non-dutiable as cleaning not related to a dutiable repair)).

In the case of item 403, we note that there are other portions of this item (relating to IGS piping inspection and repairs) which are clearly dutiable (and which are conceded to be dutiable by the applicant). We note that the ABS Survey worksheet and other information which could possibly clarify whether the portion of item 403 in controversy consisted of work performed in conjunction with dutiable repairs (ABS Report UL 5475-F) is not included in the file. Because of the presence of these dutiable repairs in item 403 which may be related to the cleaning in controversy, and because of the absence of evidence which could possibly clarify the matter, we conclude that the portion of this item in controversy is dutiable.

In the case of the work described in the Cheung Hae invoice, there is no indication that this work was performed in conjunction with repairs (see invoice items 701-703, concerning tank repairs, and note that those items provide separately for cleaning (referring to invoice item 005)). Therefore, we conclude that this item is non-dutiable (see above authorities in regard to cleaning and, in particular, ruling 111730).

The applicant claims that the cost in the Halla Marine 03/13/95 invoice (purchase of an anchor chain) is exempt from the 50% duty in 19 U.S.C. 1466(a) under section 1466(h)(3), citing the above-referenced May 31, 1995, memorandum (113291). The May 31, 1995, memorandum defines a "part", for purposes of section 1466(h), as "... something which does not lose its essential character or its identity as a distinct entity but which, like materials, is incorporated into a larger whole." The definition also states that "[i]t would be possible to disassemble an apparatus and still ... readily identify a part." An anchor chain meets this definition (it does not lose its essential character or identity but is incorporated into a larger whole and it would be possible to disassemble an apparatus and still readily identify the anchor chain) (see also ruling 112202, May 20, 1992, invoice item 14, holding that an anchor chain kit may qualify for treatment under section 1466(h)(2)). Therefore, if the other requirements (proper filing of a vessel repair entry and appropriately completed continuation sheets for consumption entries and payment of applicable duty) for treatment under section 1466(h)(3) are met (we note that the vessel repair entry and continuation sheets have been filed), this item is dutiable under section 1466(h)(3) and is not subject to the 50% duty under section 1466(a).

The applicant claims that item 002 (services and facilities) is subject to apportionment (or proration) on the basis of dutiable and non-dutiable foreign costs or duty-free as electricity, air, water, telephone, etc.; staging, crane service, or rigging; cleaning; drydocking; charges for other than equipment, repairs, or labor in connection therewith; or consumables (the applicant concedes that the portions of this item consisting of protective covering (C.14 and C.15) are dutiable). We have taken the position that charges such as those in controversy in this item, basically consisting of drydocking and related charges, are subject to the same apportionment rule Customs has long followed for gas-freeing costs (see C.I.E. 1188/60) (see ruling 226826, May 2, 1996, invoice item 002). Therefore, the costs in this item are subject to apportionment (or proration) on the basis of dutiable and non-dutiable foreign costs.

(As noted above, the decision in Texaco is applicable to this entry. Therefore, portions of many of the items relating to dutiable repairs (e.g., staging) may be dutiable under the "but for" test approved in that case. In this regard, you should be guided by that case, the rulings regarding this issue referred to in this ruling (copies provided), and the January 18 and March 3, 1995, memorandums from the Assistant Commissioner referred to above.)

HOLDING:

Among the items about which you requested advice, items 329, 330, 401 (including only the portion in controversy), 414, 415, 419, 420 (the portion in controversy), 425, 605, 901, and the Cheung Hae 03/15/95 invoice are NON-DUTIABLE. Items 108 (the portion in controversy, including staging) and 403 (the portion in controversy), are DUTIABLE. The cost in the Halla Marine 03/13/95 invoice qualifies as the cost of a spare part within the meaning of 19 U.S.C. 1466(h)(3) and, provided that the requirements in that provision are met (see above), this item is dutiable under section 1466(h)(3) and is not subject to the 50% duty under section 1466(a). The costs for the portions of item 002 in controversy are subject to apportionment (or proration) on the basis of dutiable and non-dutiable foreign costs.

Sincerely,

William G. Rosoff Chief

Previous Ruling Next Ruling