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HQ 557462

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September 13, 1994

CLA-2: CO:R:C:S BLS

CATEGORY: CLASSIFICATION

TARIFF NO.: 9801.00.10, 9802.00.50, 9802.00.80 4811.90.80, 4819.20.0040, 4819.40.0040,
4819.50.4060, 3926.40.00

District Director of Customs
P.O. Box 3130
Laredo, Texas 78044-3130

RE: Applicability of GSP to certain gift wrapping and packaging articles; subheadings 9801.00.10, 9802.00.50, 9802.00.80; sets

Dear Madame:

This is in reference to a letter dated July 7, 1993, from V. Alexander & Co., Inc., ("Alexander"), concerning the tariff treatment of certain gift wrapping and packaging articles imported from Mexico by Artfaire-C.P.S. Corporation ("CPS"). The inquirer requests a ruling as to the applicability of the Generalized System of Preferences (GSP), and subheadings 9801.00.10, 9802.00.50 and 9802.00.80, Harmonized Tariff Schedule of the United State (HTSUS), to the imported articles as well as the classification of the items.

The request pertains to 1993 entries only which remain unliquidated pending our decision. Alexander has advised that CPS is no longer doing business in Mexico, and accordingly, the request for our opinion regarding country of origin marking has been withdrawn. While photographs of the various ensembles and other items were included with the request, no actual samples have been received by this office.

We would also note that since Mexico's designation as a BDC for purposes of the GSP expired on the date that the North American Free Trade Agreement (NAFTA) became effective (January 1, 1994), our analysis of GSP entitlement applies only to entries filed prior to that date. Articles imported on or after January 1, 1994, will receive duty-free treatment only if they qualify as "originating goods" under the NAFTA. A discussion of this issue is beyond the scope of this ruling.

FACTS:

1) 2-Roll Gift Wrap Ensemble

The 2-roll gift wrap ensemble is presented in a paperboard gift box that can be used as such after purchase. As imported, it contains the following components: 2 rolls of gift wrapping paper; gift tags; pull-out bows; 3 spools of ribbon; ribbon hanks; printed and solid tissue sheets; gift cards; and a bow- tying instruction sheet. All of the components for this ensemble, with the exception of the gift wrap, are furnished ready for repackaging.

The materials used to produce the gift wrap consist of 830 feet reams of gift wrap paper (in various widths), liquid adhesive, adhesive tape, and spools of cardboard which produce the finished rolls of gift wrap paper for the ensemble. In Mexico, the spool of 3-inch wide cardboard is placed on a spindle and pulled through a section of machinery that applies adhesive to one side of the cardboard and then is spiral-wound at an angle onto an iron rod in one continuous motion. The cardboard tubing produced from the process is then cut to a pre-determined length (the width of the gift wrap paper to be wound onto it). The cardboard gift wrap tubes are then taken and placed onto the hopper of the gift wrap paper roll winding machine.

In this process, the gift wrap paper ream is placed onto a ream rolling machine where the paper is pulled through feed rollers. A cardboard tube is then systematically lowered in place from the tube bin where as the gift wrap paper begins to wind itself onto the cardboard tube, a 1-inch strip of adhesive tape is applied to the gift wrap paper and cardboard tube to prevent slippage during the winding process. The gift wrap paper is then cut after a pre-determined length of the paper has been wound onto the tube and a second 1-inch strip of adhesive tape is applied onto the gift wrap paper to prevent unwinding during packaging. The end product is the gift wrap paper roll which will be placed in the ensemble. Alexander states that all of the materials used to produce the gift wrap paper and the other components in the ensemble are of U.S.-origin.

2) The 3-Roll Gift Wrap Ensemble

The 3-roll gift wrap ensemble is presented in a clear plastic tray. It contains 3 rolls of gift wrapping paper; finished bows; ribbon coils; and gift tags. The process used to create the gift wrap paper in this ensemble is identical to the process used to create the gift wrap paper for the 2-roll
ensemble.

The importer also supplies 500 yard bolts of ribbon, spools of stick-on tags, and spools of staple wire which produce the finished bows for the ensemble. The bolt of ribbon is placed on a spindle and pulled through a section of machinery that will pierce the ribbon through the "U-shaped" staple wire and continue to pull, rotate and pierce the ribbon until a gift bow is formed. The machine then completes the process by applying the sticky tag through the staple wire, closing the staple ends off and cutting off the completed bow from the continuous strand of ribbon. The completed bow is then mechanically tossed into an awaiting box to be manually placed into the ensemble.

The ribbon coils are produced from the same bolts of ribbon that have been placed on a coil winding machine. The ribbon is pulled from the bolt and run through a series of spindles which winds the ribbon into a coil of a pre-determined length. The ribbon is then cut and a strip of adhesive tape is mechanically applied onto the ribbon coil to prevent the ribbon from unwinding during packaging. Alexander states that all of the components used in producing the 3-roll gift wrap ensemble are of U.S- origin.

3) Gift Bag

The gift bag is made of wrapping paper. Some are made with what looks like (from the photograph) a textile cord handle; others do not have handles.

In Mexico, a gift wrap paper ream is placed onto a ream rolling machine where the paper is pulled through feed rollers. The gift wrap paper is systematically shaped, creased, folded, and cut to the length of the desired gift bag. The completed folded and shaped gift bag continues through the machine where liquid adhesive is placed onto the bottom end of the bag and compressed to secure the folds that enclose the bag. In a separate process involving some of the bags, handles will be glued onto the inside of the bag and a peel-off paper backer will be applied on top of the glued handle and also on the inside of the bag to provide stability to the handle.

The gift bags will be imported in bulk or as part of a gift bag ensemble presented in a clear polyester bag that contains, in addition to the bag, gift cards, ribbon hanks, and an instruction booklet. Alexander states that all of the components used in producing the gift bags are of U.S.-origin.

(4) Treasure Chest Box

The treasure chest box is a pre-wrapped gift box. It is made of paperboard in two parts. The external part of the box, covered with wrapping paper, is open at one end, into which the internal sleeve part of the box that holds the box's contents is inserted. According to the photograph provided, the gift box appears to be the size required to hold a dress shirt or blouse, or perhaps a sweater. For this purpose, these boxes fold up for convenient packaging.

In producing the box, cardboard sheets are manually fed into a machine which has been fitted with die press/die cut plates which crease and cut to size and shape the inserted sheet. The box cutout is then taken to a separate area of the facility to have it manually removed from the sheet, where it will be seam glued with liquid adhesive on one side to form an open ended box.

After the adhesive has dried, a pre-cut sheet of gift wrap paper is manually wrapped around the box and manually secured with two 1-inch strips of adhesive tape. The slide-out cardboard sleeve is then manually placed into the open-ended cardboard box where it will be manually packaged for shipping in bulk as a pre- wrapped gift box with an inner box sleeve in a knock-down state.

5) Treat/Treasure Gift Box, Pyramid Gift Box, Gift Box Tote

The identity of these articles is somewhat confused. At the bottom of page 5 of the July 7, 1993, letter, after describing the production process, the articles are identified as (a) an open-ended laminated gift box, (b) laminated treasure/treat box, and (c) a gift box tote (laminated with wrapping paper). These three boxes are further described in the next few paragraphs, of the letter, but the treat/treasure box appears to be identified as a laminated pyramid box. In any event, these articles are described together in the letter because they are made from the same wrapping paper-covered paperboard material that is cut to shape to form them. The open-ended laminated gift box is not further described; it is likely capable of folding. The laminated pyramid box has a cord handle that is made from either paper or textile material. (It cannot be determined from the photograph.) It is capable of folding. The gift box tote has braided rope handles and a removable box top-like cover. Whether it is capable of folding is unknown.

The lamination machine is equipped to hold a full ream of gift wrap paper, and a vat of liquid adhesive. It is designed to apply a thin film of liquid adhesive onto the gift wrap paper as
it is pulled through the rollers. Once the adhesive has been applied, the paper is cut to a pre-determined length by the machine and compressed onto the cardboard sheet which is being manually fed into the unit.

The laminated cardboard sheets are then manually fed into a second machine which has been fitted with die press/die cut plates which crease and cut to size and shape the inserted laminated sheet. The box cutout is then taken to a separate area of the facility to have it manually removed from the seat, where it will be seam-glued with liquid adhesive on one side to form either an open ended laminated gift box, laminated treat/treasure box or a gift box tote.

The open-ended laminated gift box is imported either in bulk or as part of an ensemble. The ensemble includes the box, gift cards, ribbon hanks, and an instruction booklet. The laminated pyramid box is also imported in bulk or as part of an ensemble, and includes an assortment of boxes (we assume to mean at least two or more, in either various sizes or perhaps various colors or patterns), box handles, gift cards, ribbon hanks, and an instruction booklet. The handles consist of a piece of cording cut by hand from a spool to a pre-determined length, and placed manually into the knock-down pyramid box for assembly by the ultimate consumer.

The gift box tote is then sent to an area of the facility where it could undergo further processing for specialty orders such as foil stamping or die sinking. A pair of holes are punched on two sides of the gift box tote in a separate process so that a strand of pre-cut braided rope can be inserted through the holes and knotted at the ends to create two separate handles. Upon completion, the tote will be packaged in bulk for import into the United States. Alexander states that all of the components used in producing the treasure gift box, the pyramid gift box, and the gift box tote, are of U.S.-origin.

6) Bow Tube/Candy Tube

The bow/candy tube is a cylinder of paperboard covered with wrapping paper. It has plastic end covers and a braided rope handle at the tip end. It is imported either filled with finished bows and ribbon hanks or empty. The tube could be used as a gift package after purchase or, if imported empty, to hold various items for retail sale, such as candy or other products.

In Mexico, wrapping paper is cut to length from the U.S.- origin reams. Sheets of gift wrap paper are glued by hand onto
the cardboard tubes. Two holes are pierced into the top side of the tube to create an avenue for the tube handle. A hand- measured piece of braided rope is cut to length and inserted into each hole and knotted from the inside to secure the handle in place. The tube is now prepared to be packaged with bows and ribbon hanks.

The importer supplies 500 yard bolts of ribbon, spools of stick-on tags, and spools of staple wire which produce the finished bows for the ensemble. The bolt of ribbon is placed on a spindle and pulled through a section of machinery that will pierce the ribbon through the "U-shaped" staple wire and continue to pull, rotate and pierce the ribbon until a gift bow is formed. The machine then completes the process by applying the sticky tag through the staple wire, closing the staple ends off and cutting off the completed bow from the continuous strand of ribbon. The completed bow is then mechanically tossed into an awaiting box to be manually placed into the ensemble. Finally, the bows and ribbon hanks are placed into the cardboard tube by hand and then sealed with the plastic end caps. Alexander states that all of the components used to produce the bow tube/candy tube are of U.S.-origin.

ISSUE:

1) What is the proper classification of the above-described paper and paperboard gift boxes, bags, and wrapping/packaging ensembles?

2) Whether the GSP, or subheadings 9801.00.10, 9802.00.50, and 9802.00.80, HTSUS, are applicable to the imported articles.

CLASSIFICATION

Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is governed by the General Rules of Interpretation (GRI). GRI 1 provides that classification is determined in accordance with the terms of the headings and any relative section or chapter notes. Where goods cannot be classified solely on the basis of GRI 1, the remaining rules will be applied in sequential order.

The Explanatory Notes (EN'S) to the Harmonized Commodity Description and Coding System constitute the official interpretation of the nomenclature at the international level. While not legally binding, they represent the considered views of classification experts of the Harmonized System Committee. It has been the practice of the Customs Service to follow, whenever
possible, the terms of the EN's when interpreting the HTSUS. In Treasury Decision (T.D.) 89-80, Customs stated that the EN's should always be consulted as guidance when classifying merchandise. (See T.D. 89-80, 23 Cust. Bull, 379 (1989), 54 Fed. Reg. 35,127 (August 23, 1989).) (See also Totes, Inc. v. United States, No. 91-09-00714, Slip Op. 92-153 (CIT September 4, 1992), 26 Cust. Bull. No. 40, 35, 37 n. 3 (September 30, 1992), citing T.D. 89-80 and acknowledging the authority of the EN's.)

The above GRI's and EN's are applied to classify the merchandise at issue, as set forth below.

1) The 2-Roll and 3-Roll Gift Wrap Ensembles

The 2-roll and 3-roll ensembles are not classifiable according to GRI 1, since both are articles consisting of multiple components. Under GRI 2(b), goods consisting of more than one material or substance should be classified according to the principles of GRI 3. Under GRI 3(b), goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified according to GRI 3 (a), are to be classified as if they consisted of the material or component that gives them their essential character.

It is our opinion that the gift wrap ensembles are sets as contemplated under GRI 3(b). Under the EN's for GRI 3(b), the concept of "sets" is set forth as follows:

(x) For the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which:

(a) consist of at least two different articles which are, prima facie, classifiable in different headings;

(b) consist of products or articles put up together to meet a particular need or carry out a specific activity; and

(c) are put up in a manner suitable for sale directly to users without repacking.

The gift wrap ensembles meet all of the above criteria. As sets, they will be classified, under GRI 3(b), as if consisting entirely of the component that imparts essential character. In each case, we believe that the wrapping paper imparts essential
character to the ensembles. Therefore, both the 2-roll and 3- roll gift wrap ensembles will be classified under the tariff provision applicable to the ensemble's wrapping paper.

However, no samples were submitted for laboratory analysis, and the inquirer's letter does not provide the detailed information necessary to allow us to classify the wrapping paper. We note that we previously issued a ruling on behalf of the importer classifying similar merchandise. In New York Ruling (NYRL) 879432, dated November 23, 1992, we classified as a set a gift wrapping ensemble according to the classification of the wrapping paper component. That set consisted of two rolls of decorative wrapping paper, six made-up bows of plastic ribbon, two reels of subheading 4811.90.80, HTSUS, which provides for other (than certain described) surface decorated paper, in rolls or sheets, weighing over 30 g/square meter. If the wrapping paper of the 2-roll and 3-roll ensembles is the same as that classified in NYRL 879432, then classification of the ensembles will be under subheading 4811.90.80, HTSUS.

Heading 4811, HTSUS, covers the following kinds of paper: "Paper, paperboard, cellulose wadding and webs of cellulose fibers, coated, impregnated, covered, surface-colored, surface- decorated or printed, in rolls or sheets, other than goods of heading 4803, 4809, 4810 or 4818." If the wrapping paper of the ensembles is not the same as that classified in NYRL 879432, but falls within the description of heading 4811, HTSUS, it will be classifiable under that heading. Without a sample to analyze, we cannot be more specific. We suggest that the inquirer submit to the appraising officer a sample of the wrapping paper from each ensemble for laboratory analysis and correct classification.

2) The Gift Bag

The gift bags, with or without handles, imported in bulk are classifiable, under GRI 1, in subheading 4819.40.0040, HTSUS, which provides for paper bags other than certain described sacks and bags. The gift bag ensembles appear to qualify as sets. As sets, they also would be classifiable under that subheading, since the gift bag, under GRI 3(b), would impart essential character to the gift bag ensemble.

3) Treasure Chest Box (pre-wrapped Gift Box)

The treasure chest gift box is classifiable, under GRI 1, in subheading 4819.20.0040, HTSUS, which provides for other (than certain described) folding cartons, boxes, and cases of non- corrugated paper or paperboard.

4) Treat/Treasure Gift Box, Pyramid Box, Gift Tote Box

The laminated open-ended gift box, if capable of folding, is classifiable, under GRI 1, in subheading 4819.20.0040, HTSUS, which provides for other (than certain described) folding cartons, boxes, and cases of non-corrugated paper or paperboard. The gift box ensemble appears to qualify as a set. Thus, under GRI 3(b), it would be classifiable under the same subheading, since the ensemble would take its essential character from the box. If the box is not capable of folding, it would be classifiable, as an individual article or as a set, under subheading 4819.50.40.40, HTSUS, which provides for other packing container, including rigid boxes.

The pyramid gift box is classifiable, under GRI 1, in subheading 4819.20.0040, HTSUS, which provides for (other than certain described) folding cartons, boxes, and cases on non- corrugated paper or paperboard. If the pyramid box is imported as a component of an ensemble, the ensemble would qualify as a set under GRI 3(b). Classification would be the same, since the box would impart essential character to the ensemble.

The gift box tote is made from the same laminated (wrapping paper-covered) paperboard sheet as the above two boxes. It appears from the photograph to be box-like in shape, since it is rectangular with squared corners and it has a box top. However, with the attached handles at the open end (the end over which the box top fits), and the top removed, it also appears to be like a bag. A box does not usually have handles of this sort for carrying and a bag does not usually have a box-like top. Without having a sample for a visual examination, and without more information as to how this article is used, we are unable to classify it.

5) Bow Tube/Candy Tube

The bow tube is imported both empty and filled with six made-up bows and six ribbon hanks. Empty, the tube is classifiable, under GRI 1, in subheading 4819.50.4060, HTSUS, which provides for other packing containers of paperboard. Filled with its contents of bows and ribbon hanks, the tube, as a set under GRI 3(b), is classified according to the classification of the bows, from which the set takes its essential character. Assuming that these bows are made from strips of plastic ribbon, they are classifiable under subheading 3926.40.00, HTSUS, which provides for other articles of plastic, statuettes, and other ornamental articles. (See Headquarters Ruling Letter (HRL) 954905, dated September 13, 1993, which classified decorative
plastic bows under that subheading.) Thus, the tube filled with bows and ribbon hanks would be classifiable under that subheading. (If not made from plastic ribbon, this classification decision is not applicable to the filled tube.)

Eligibility for Duty-Free or Partial Duty-Free Treatment

1) 2-Roll and 3-Roll Gift Wrap Ensembles

Under the GSP, eligible articles the growth, product or manufacture of a designated beneficiary developing country (BDC) which are imported directly into the Customs territory of the U.S. from a BDC may receive duty-free treatment if the sum of (1) the cost or value of materials produced in the BDC, plus (2) the direct costs of the processing operations in the BDC, is equivalent to at least 35 percent of the appraised value of the article at the time of entry. See, 19 U.S.C. 2463(b).

Prior to January 1, 1994, Mexico was a designated BDC. See, General Note 3(c)(ii)(a), HTSUS, predecessor to General Note 4(a), HTSUS. We will also assume, for GSP purposes only, that the gift wrap ensembles are classifiable under HTSUS subheading 4811.90.80, a GSP-eligible provision. Therefore, the ensembles will qualify for duty-free treatment, provided they are "products of" Mexico, and the 35 percent value-content requirement is satisfied.

Prior to August 20, 1990, the GSP program differed from the Caribbean Basin Economic Recover Act (CBERA) and U.S.-Israeli FTA programs in that the latter programs included a "product of" requirement, while the GSP did not. This requirement means that to receive duty-free treatment, an article either must be made entirely of materials originating in the beneficiary country or, if made of materials from a non-beneficiary country, those materials must be substantially transformed in the beneficiary country into a new or different article of commerce. In Madison Galleries, Ltd. v. United States, 688 F. Supp. 1544 (CIT 1988), aff'd, 870 F.2d 627 (Fed. Cir. 1989), the court concluded that, under the GSP statute, it is unnecessary for an article to be a "product of" a GSP country to be eligible for duty-free treatment under that program. However, section 226 of the Customs and Trade Act of 1990 (Public Law 101-382) included an amendment to the GSP statute requiring an article to be a "product of" a GSP country for it to receive duty-free treatment. This amendment was effective for articles entered, or withdrawn from warehouse for consumption, on or after August 20, 1990. See T.D. 91-7 dated January 16, 1991 (25 Cust. Bull. 7).

In T.D. 91-7, Customs held that, as a general rule, a collection classifiable in one subheading pursuant to the GRI's will receive CBERA treatment only if all of the items or components in the collection are considered "products of" the beneficiary country. To illustrate the application of the "product of" requirement to sets under the CBERA, we used the example of a hairdressing set consisting of a comb, brush and scissors manufactured in Jamaica from materials originating in Jamaica, and an electric hair clipper manufactured in Taiwan (a non-BC country) which is imported into Jamaica for packaging with the other items of the set. We stated that in cases where the entire imported set is not the "product of" a BDC, as required by the CBERA statute, neither the set nor any part thereof would be entitled to duty-free treatment under this program. The above requirements also exist under the GSP statute with respect to articles entered on or after August 20, 1990.

In Superscope, Inc. v. United States, 13 CIT 997, 727 F. Supp. 629 (1989), the court held that certain glass panels of U.S.-origin that were exported, repacked abroad with certain foreign components, and returned to the U.S. as part of unassembled audio cabinets, were entitled to duty-free entry under item 800.00, Tariff Schedules of the United States (TSUS) (predecessor to subheading 9801.00.10, HTSUS), since the U.S. panel portion of the imported article was "not 'advanced in value or improved in condition. . . while abroad,' but [was] merely repacked." Id. at 631. Although the Superscope case concerned the TSUS, not the HTSUS, the decision is believed to be equally applicable to similar situations arising under the HTSUS, since item 800.00, TSUS, and relevant Schedule 8, TSUS, headnotes, were carried over virtually unchanged into the HTSUS.

In Headquarters Ruling Letter (HRL) 556797 (and HRL 556798) dated September 23, 1993, involving the eligibility for GSP treatment of certain catheter kits considered to be sets, we found that based on the decision in Superscope, the U.S. components which qualified for duty-free treatment under subheading 9801.00.10, HTSUS, were to be excluded from the set for purposes of determining whether the kits qualified as "products of" Mexico under the GSP, provided the documentary requirements of section 10.1, Customs Regulations (19 CFR 10.1) were met.

Based on these authorities, we find that the U.S.-origin items furnished ready for repackaging (gift tags, ribbon spools, pull-out bows, ribbon hanks, tissue, sheets etc.), which have not been advanced in value or improved in condition by a process of manufacture or other means, and which otherwise qualify for duty-
free treatment under subheading 9801.00.10, HTSUS, are excluded from the gift wrap sets for purposes of determining whether the imported articles qualify as "products of" Mexico under the GSP. The subsequent issue to be resolved is whether the imported ensemble, excluding those items eligible for duty-free treatment under subheading 9801.00.10, HTSUS, are "products of" Mexico for purposes of the GSP.

Where, as in this case, the articles are made from materials imported into the BDC, the article will be considered the "product of" the BDC only if the materials are substantially transformed in the BDC into a new or different article of commerce. Customs has previously held that the test for determining whether a substantial transformation has occurred is whether an article emerges from a process with a new name, character or use, different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 69 CCPA 152, 681 F.2d 778 (1982).

In general, Customs has held that cutting or shaping materials to defined shapes or patterns suitable for use in making finished articles, as opposed to mere cutting to length or width which does not render the article suitable for a particular use, constitutes a substantial transformation. See, e.g., HRL 555702 dated January 7, 1991 (steel plates dedicated to use in the final article by cutting, folding, binding, scraping, etc., considered substantially transformed components) and HRL 553574 dated August 15, 1985 (aluminum strip cut to length, punched and/or drilled with holes, and notched, which gave strip specific shape or pattern, was substantially transformed.)

Similarly, in the instant case, (with respect to the gift wrap paper in both the 2-roll and 3-roll ensembles), the cardboard component prior to processing is a "generic" material from which a variety of products may be created. However, after cutting to length, applying adhesive, and spiral-winding, the cardboard material is dedicated for use as a holder of wrapping paper or other paper products. This component has a new name, character and use distinct from the material from which it was made, and, in accordance with the cited authorities, has undergone a substantial transformation.

The next issue which must be addressed is whether the assembly of the wrapping paper component to the cardboard tube also substantially transforms this component into a different article of commerce.

We have held that, for purposes of the GSP, an assembly
process will not work a substantial transformation unless the operation is "complex and meaningful." See C.S.D. 85-25, 19 Cust. Bull. 544 (1985). Whether an operation is complex and meaningful depends on the nature of the operation. Some of the factors that we consider in making this determination are the time, cost, and skill involved, the number of components assembled, the number of different operations, the attention to detail and quality control, as well as the benefit accruing to the BDC as a result of the employment opportunities generated by the manufacturing processes performed there.

Applying these principles to the facts in this case, we find that the process of cutting the wrapping paper to length, and affixing it to the cardboard tube with 1-inch strips of adhesive is a simple assembly process requiring little skill, and does not constitute a "complex and meaningful" operation. Further, in the final assembly, there is no real integration of the cardboard tube and the wrapping paper where the latter component loses its separate identify. Belcrest Linens v. United States, 741 F. 2d 1368, 1373 (Fed Cir. 1984). Accordingly, this assembly does not constitute a substantial transformation. Therefore since the imported set is not considered a "product of" Mexico, it will not be eligible for duty-free treatment under the GSP.

Subheading 9802.00.80, HTSUS, provides a partial duty exemption for:

[a]rticles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape, or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process, such as cleaning, lubrication, and painting.

Included among the operations considered incidental to the assembly process are cutting to length of wire, thread, tape, foil, and similar products exported in continuous length. (See 19 CFR 10.16 (b)(6).) T.D. 91-7, supra, also provides that subheading 9802.00.80, HTSUS, is applicable to situations in which a portion of a set or mixed or composite goods, consists of components or items assembled abroad in whole or in part of U.S- origin fabricated components.

In connection with the 2-roll ensemble, we find that the process of assembling the U.S.-origin fabricated component,
wrapping paper, to the cardboard tube, by cutting to length and affixing the components to each other by means of adhesive tape, are acceptable assembly operations or operations incidental to assembly. Therefore, duties will be assessed pursuant to subheading 9802.00.80, HTSUS, upon the full value of the set less the cost or value of the U.S. fabricated components (wrapping paper, adhesive tape). The 3-inch wide cardboard and the liquid adhesive are not eligible for the partial duty exemption under this provision, since they have been further fabricated in Mexico. (As discussed above, the U.S.-origin items that are merely repackaged with the set will receive duty-free treatment under subheading 9801.00.10, HTSUS, provided all documentary requirements are satisfied.)

Our findings with respect to the applicability of subheading 9801.00.10, HTSUS, and GSP, to the 2-roll ensemble, are equally applicable to the 3-roll ensemble, since this set also includes repackaged items of U.S.-origin, and the operations involving production of the gift paper are identical. Thus, those items of U.S.-origin which are merely repackaged with the set (gift tags) will be afforded duty-free treatment under subheading 9801.00.10, HTSUS, assuming all documentary requirements are satisfied. Further, since the gift wrap paper has not undergone a substantial transformation, the imported set is not considered a "product of" Mexico, and it is not eligible for duty-free treatment under the GSP.

Similarly, subheading 9802.00.80, HTSUS, will also be applicable to the imported 3-roll ensemble since the assembly operations involved in affixing the wrapping paper to the cardboard tube are identical to the operations performed in connection with the 2-roll ensemble. Thus, an allowance in duty will be permitted for the cost or value of the wrapping paper component and the adhesive tape. However, since two additional components are included with this ensemble (ribbon bows and ribbon coils), the issue which must now be addressed is whether the cost or value of these U.S.-origin components may also be deducted from the full value of the set under HTSUS subheading 9802.00.80.

We have previously held that cutting U.S. ribbon to appropriate lengths abroad, forming one or more pieces of ribbon into the shape of a bow, and then tying the center of the bow with coated or tinsel wire to secure the bow shape constitutes an acceptable assembly or operation incidental to assembly under subheading 9802.00.80, HTSUS, or item 807.00, TSUS (the precursor provision to subheading 9802.00.80, HTSUS). See, Headquarters Ruling Letters (HRL) 071450 of September 8, 1983, 553674 of June 14, 1985, 554956 of April 6, 1988, and 554943 of April 18, 1988.

We have also held in HRL 555475 of November 3, 1989, that ribbon cut to length, wrapped twice around the middle of a coat hanger bar and base of a hanger hook, and knotted into a bow qualified as an assembly operation or an operation incidental to assembly. In each of these cases, the bow formation process involved the joinder of two or more components. The ribbon's bow shape was secured either by tying wire around its center or by wrapping and knotting the ribbon to the hanger.

In addition, in HRL 555357, dated February 16, 1990, we found that the formation of a single ribbon into a bow by knotting the ribbon is not, in itself, an assembly operation. That case involved cut-to-length ribbon which was placed on a bow maker machine to form a bow which was tied to itself. The bow was then tacked to certain footwear prior to importation. HRL 555357 is distinguishable from the above-cited rulings as the single length of ribbon was the sole component which was knotted to form a bow. There was no joinder of two or more separate components as required by HTSUS subheading 9802.00.80. However, we have also held that forming a ribbon into the shape of a rose and sewing the ribbon rose to itself to retain its shape are acceptable assembly operations or operations incidental to assembly. See, HRL 555476 dated February 23, 1990, in which we cited L'eggs Products Inc. v. United States, 704 F. Supp. 1127 (1989), in support of our decision. In L'eggs, the sewing of knit tubes or leg blank portions of pantyhose closed by thread was held to be an acceptable assembly operation. Thread was used to join the tube to itself by sewing the tube ends closed. The court held that "[s]ince the tube closing operation joined two components together, namely thread and fabric, it is an 'assembly'..."

The process in creating the bow under the facts presented herein is analogous to the operations performed in HRL 555476. Thus, a 500 yard bolt of ribbon is placed on a spindle, machine- pulled and rotated through a "U-shaped" staple wire until a gift bow is formed. The process is completed when a "sticky tag" is applied through the staple wire, closing off the staple ends and cutting off the completed bow from the continuous strand of ribbon. The staple in this case, which holds the bow together, performs the same function as the thread in HRL 555476, and in L'eggs. Accordingly, a partial duty exemption will be allowed under subheading 9802.00.80, HTSUS, for the cost or value of the U.S. fabricated components comprising the assembled bow.

We also find that the process used to create the ribbon coils constitute an acceptable assembly operation. During this process, ribbon is pulled from the ribbon bolt, run through a
series of spindles which winds the ribbon into a coil of pre- determined length. The ribbon is the cut and a strip of adhesive tape is mechanically applied onto the ribbon coil to prevent unwinding during packaging. The ribbon remains a U.S. fabricated component during this process, and the creation of these items qualifies as assembly operations or operations incidental to assembly in accordance with the cited authorities. The adhesive tape performs a function similar to the staple, above, and the thread in HRL 555476, and L'eggs. Accordingly, a partial duty allowance under HTSUS subheading 9802.00.80, will also be allowed for the cost or value of the components comprising the assembled ribbon coil. (We also find that the foreign operations involved in processing the ribbons are alterations within the meaning of subheading 9802.00.50, HTSUS. See HRL 554179 dated September 10, 1986, where we held that U.S. ribbon exported in spool lengths of 400-500 yards, cut to length, and returned to the U.S. in shorter lengths, was dutiable upon return only on the cost or value of the foreign alterations performed abroad. The operations in the instant case are analogous, as the exported ribbon and adhesive tape are complete for this intended use prior to the foreign processing.)

2) Gift Bag

As provided above, the gift bags are classifiable under subheading 4819.40.0040, HTSUS, a GSP-eligible provision. The operations used to produce this item involve placing the wrapping paper ream through the feed roller, shaping, creasing, folding, cutting to length, and securing the folds that enclose the bag by gluing. In some cases, a handle will be attached also by gluing.

We believe that for purposes of determining GSP eligibility, the involved operations are "complex and meaningful" as that term is used in C.S.D. 85-25. See above. In making this determination, we note that the finished item is a new and different article of commerce with a name, character and use clearly distinguishable from the material (wrapping paper) from which it was made. Accordingly, we find that the gift bag is the result of a substantial transformation of the wrapping paper (and glue), and therefore is considered a "product of" Mexico. The guestion which must now be addressed is whether the cost or value of the materials used to produce the bag may be included in calculating the 35% value-content requirement under the GSP.

If an article is comprised of materials that are imported into the BDC, the cost or value of those materials may be counted toward the 35% value-content minimum only if they undergo a double substantial transformation in the BDC. See section

10.177, Customs Regulations (19 CFR 10.177), and Aztec Milling Co. v. United States, 703 F. Supp F. Supp. 949 (CIT 1988), aff'd, 890 F.2d 1150 (Fed. Cir. 1989). That is, the cost or value of the imported materials used to produce the gift bag may be included in the GSP 35% value-content computation only if they are first substantially transformed into a new and different article of commerce, which is itself substantially transformed into the final product.

In the instant case, an article of commerce is not produced until the gift bag is completed. Therefore, the required operations do not result in an intermediate article of commerce. The addition of a handle, in some cases, to the bag, does not change this result, since we consider the bag with or without the handle to be essentially the same article of commerce. Thus, the bags are entitled to GSP treatment only if the direct costs of processing incurred in Mexico represents at least 35% of the bags' appraised value.

We also find that the gift bags imported without the handles do not qualify for the partial duty exemption under subheading 9802.00.80, HTSUS, since the wrapping paper is the sole solid component used to form the item. (Glue is not considered a solid component.) The creation of the gift bag without handles does not involve a joinder of two or more separate components as required by subheading 9802.00.80, HTSUS. See also HRL 555357, supra. However, the bags imported with handles do qualify for the exemption, as two separate components are involved, and the process otherwise constitutes an acceptable assembly operation or an operation incidental to assembly under the statute. (Under section 10.16(a), Customs Regulations (19 CFR 10.16 (a)), assembly operations may consist of any method used to join or fit together solid components, such as welding, soldering, riveting, force fitting, gluing, etc. In this regard, we assume for these purposes that the handles are made of cord or rope of U.S.- origin, are cut from a spool of either of these materials, and are attached to the bag in this condition by gluing.) Accordingly, an allowance in duty may be made for the cost or value of the cord or rope -- the U.S. fabricated component advanced in value or improved in condition only by the assembly process or by an operation incidental to assembly. (The gift bag component is not eligible for the allowance since it has been fabricated in Mexico.)

When imported as part of an ensemble, those items sent abroad for repackaging only with the imported gift bag will be eligible for duty-free treatment under subheading 9801.00.10,

HTSUS, provided the documentary requirements are satisfied. (See 2-Roll and 3-Roll Gift Wrap Ensembles, above.)

Further, in accordance with our analysis, above, in connection with the gift wrap ensembles, the items qualifying for HTSUS subheading 9801.00.10 treatment, will not be considered in determining whether the gift bag ensemble qualifies as a "product of" Mexico. However, the gift bag ensemble will be eligible for GSP treatment only if all of the remaining items or components in the set are considered "products of" Mexico. An allowance in duty may be made under subheading 9802.00.80, HTSUS, for the cost or value of the U.S. fabricated cord or rope used as the handle for the gift bag, as described above.

3) Treasure Box (GSP eligibility)

The operations involved in creating the cardboard box component of this article (classified under subheading 4819.20.0040, HTSUS, a GSP-eligible provision), i.e., creasing and cutting the cardboard sheets into specific shapes, open- ended boxes, and seam-gluing with liquid adhesive, are analogous to the operations performed in connection with the production of the gift wrap cardboard cylinder which we held was the result of a substantial transformation. In both cases, the cardboard material is cut and shaped, through bending, creasing, or otherwise, to form an article with a new name, character and use distinct from the material from which the article was made. (See GSP-eligibility analysis in connection with gift wrap ensembles, above, and HRL 553878 dated October 28, 1985 (raw dimension lumber and plywood sheets cut and shaped into various components, i.e., cabinet doors, drawers, draw fronts, etc, for assembly into cabinets.))

However, we are also of the opinion that the subsequent assembly of the wrapping paper component to the box, by means of 2 one-inch adhesive tape strips, does not constitute a substantial transformation of this item. Rather, these operations are "minimal, simple, assembly-type operations" which were not intended to constitute a substantial transformation for GSP purposes. See C.S.D. 85-25, above. Accordingly, we find that the imported treasure box is not a "product of" Mexico, and therefore is not eligible for duty-free treatment under the GSP.

We also find that a partial duty allowance under subheading 9802.00.80, HTSUS, will not be permitted for the cost or value of the U.S.-origin cardboard, since it is further fabricated in Mexico by creasing and cutting to form specific shapes. See 19 CFR 10.14(a) (materials undefined in final dimensions and shapes which are cut into specific shapes or patterns are not considered

U.S. fabricated components). For example, uncut textile fabrics exported in bolts, or other materials such as lumber, leather, sheet metal or plastic sheeting exported in basic shapes and forms to be fabricated into components for assembly are not considered fully fabricated when exported. See also HRL 556715 dated August 19, 1992 (cutting pencil slats to hexagonal shapes constitutes further fabrication of slats).

However, we find that cutting the wrapping paper component to length, and affixing it to the cardboard box with U.S.-origin adhesive tape cut to length are acceptable assembly operations, or operations incidental to assembly. Therefore, the treasure box may be entered under subheading 9802.00.80, HTSUS, with an allowance in duty for the cost or value of the wrapping paper and adhesive tape.

4) Laminated Gift Box

As described, above, this item (classifiable under subheading 4819.20.0040, HTSUS, a GSP-eligible provision), undergoes a process of lamination, which involves the application of an adhesive to the gift wrap paper roll, cutting the paper to length, and compressing it onto a cardboard sheet. The now- laminated paper is then creased by machine and cut to size and shape. The final steps involve removal of the box cut out from the sheet and seam gluing, to form the open ended gift box. An ensemble may also be created which could include gift cards, ribbon hanks, and an instruction booklet, packaged in a poly bag.

In accordance with previously-cited authorities, supra, we believe that cutting the wrapping paper to length, gluing, compressing it onto a cardboard sheet, creasing, cutting and shaping the laminated sheet, and seam-gluing, substantially transforms the U.S.-origin wrapping paper and cardboard sheet into an article, a laminated gift box, with a character, use and identity distinct from the materials from which it was made. Accordingly, we find that the laminated gift box is a "product of" Mexico for purposes of determining whether it is eligible for duty-free treatment under the GSP.

However, we do not find that during these operations an intermediate article of commerce has been produced, which in turn is itself substantially transformed into the final product. Accordingly, we find that the cost or value of the U.S.-origin components use to create the laminated gift box cannot be use in calculating the 35% value-content requirement under the GSP. Thus, the box is entitled to GSP treatment only if the direct cost of processing operations incurred in Mexico represents at
least 35% of the box's appraised value.

We also conclude that a partial duty allowance under subheading 9802.00.80, HTSUS, will not be allowed for the cost or value of the U.S.-origin cardboard and wrapping paper. As these components are further fabricated in Mexico, this provision will not be applicable. (See 19 CFR 10.14(a), and our analysis, above, concerning the Treasure Box.)

Under our previous discussion regarding classification, we stated that it appeared this ensemble would qualify as a set. We also found in connection with the gift bag ensemble, that whether or not the ensemble was considered a set, the U.S.-origin components merely repackaged with the set would qualify for duty- free treatment under subheading 9801.00.10, HTSUS. Similarly, we find that the U.S.-origin components merely repackaged with the laminated gift box, will qualify for duty-free treatment under subheading 9801.0010, HTSUS, assuming all documentary requirements are satisfied.

5) Laminated Pyramid Box

As heretofore described, the operations involved in the fabrication of this item (classifiable under subheading 4819.20.0040, HTSUS) are similar to the operations involved in creating the laminated gift box. Accordingly, for the reasons discussed above, we find that only a single substantial transformation occurs in Mexico. Therefore, while the imported article is considered a "product of " Mexico, the cost or value of the U.S.-origin wrapping paper and cardboard sheet cannot be included in calculating the 35% value-content requirement under the GSP. Thus, the box is entitled to GSP treatment only if the direct costs of processing incurred in Mexico represents at least 35% of the box's appraised value.

Additionally, since the components comprising this article are further fabricated in Mexico, a partial-duty allowance under sub-heading 9802.00.80, HTSUS, will not be available. However, those items that are merely repackaged with the pyramid box ensemble are entitled to duty-free treatment under subheading 9801.00.10, HTSUS, upon compliance with all documentary requirements. No allowance in duty may be permitted under HTSUS subheading 9802.00.80, for the cost or value of the cording cut to length from a spool and manually placed in the box, since no assembly operations are involved in this process. It is further noted that subheading 9802.00.50, HTSUS, is also inapplicable to the cording since it is incomplete for its intended use upon exportation, and the foreign processing constitutes a finishing
step in the production of the product. See e.g., HRL 554736 dated February 16, 1988 (cutting to length of rolls of tissue paper constitutes a finishing step in the manufacture of the merchandise, resulting in usable facial tissue products.)

6) Laminated Tote Box

As previously discussed, we cannot rule on the classification of this bag without examining a sample. However, we will assume for purposes of the following discussion, that, whether the item is classified as either a "bag" or a "box", it is a GSP-eligible article.

The processing of this item is essentially similar to the operations performed in connection with the other laminated articles. Accordingly, while the wrapping paper and cardboard sheet components undergo a substantial transformation, and the completed article is a "product of" Mexico for GSP purposes, we find that no intermediate article of commerce is produced, and that as a result, the required double substantial transformation has not taken place. Therefore, while the imported article is eligible for GSP treatment, the cost or value of the wrapping paper and cardboard sheet components cannot be counted in calculating the 35% value-content requirement under this provision. Thus, the value requirement must be satisfied by direct processing costs alone.

Furthermore, since the U.S.-origin components have been further fabricated abroad, a duty allowance representing their cost or value will not be allowable under HTSUS subheading 9802.00.80. However, where pre-cut braided rope is inserted through punched holes in the "box" and knotted, subheading 9802.0080, HTSUS, may be applicable. Thus, a duty allowance will be available for the cost or value of the U.S.-origin rope if it is merely cut to length abroad and is not further fabricated. These operations are considered acceptable assembly operations or operations incidental to assembly.

7) Bow Tube/Candy Tube

This item is either filled with finished bows and ribbon hanks or empty. (Pursuant to our discussion, above, regarding classification, the tube will be classifiable under HTSUS subheading 4819.50.4060, if imported empty, and HTSUS subheading 3926.40.00, if imported with plastic bows and ribbon hanks. In the latter case, the imported item will be considered a set and the set will reflect the classification of the bows, from which the set takes its essential character. In either case, the
imported items are GSP-eligible articles.

While the description of the processing in Mexico in connection with this item appears to be somewhat incomplete, we have been orally advised by Alexander that the operations involved in producing the cylinder of paperboard covered with wrapping paper are identical to the operations used to create the gift wrap paper component of the gift wrap paper ensemble, above. Therefore, our analysis with respect to GSP eligibility of those components are equally applicable to the subject items. Accordingly, we find that while the cardboard cylinder is the result of a substantial transformation, the subsequent assembly of the wrapping paper to the tube by means of adhesive tape strips and assembly to the tube of the plastic end covers and braided rope handle, does not effect a substantial transformation of these U.S.-origin components. Under the circumstances, the imported (empty) bow tube is not considered to be a "product of" Mexico, and is not eligible for duty-free treatment under the GSP. (This analysis is equally applicable where the bow tube is imported as part of a set.)

However, for purposes of HTSUS subheading 9802.00.80, assembling the U.S.-origin wrapping paper to the cardboard tube by cutting to length and affixing the components to each other by means of adhesive tape, force-fitting U.S.-origin plastic end covers onto the tube ends, and securing the pre-cut braided rope by knotting after inserting it through two holes cut on the top side of the tube, are acceptable assembly operations or operations incidental to assembly. Accordingly, duties will be assessed pursuant to HTSUS subheading 9802.00.80, HTSUS, upon the full value of the imported article less the cost or value of the U.S.-origin fabricated components (wrapping paper, adhesive tape, plastic covers, and rope).

When imported as a set, the bow tube will include ribbon hanks and bows, the latter to be produced in the exact manner as described above, with respect to the 3-roll ensemble. For the reasons discussed above under our analysis in connection with the production of the bows, we find that a partial duty exemption will be allowed under HTSUS subheading 9802.00.80, for the cost or value of the U.S. fabricated components constituting the assembled bow, which comprises part of the set.

We are further advised that the ribbon hanks consist of a length of U.S.-origin ribbon, folded over, packaged in plastic, and sent abroad in this condition to be repackaged in the bow tube. As a result, in accordance with our prior analysis, above, upon importation of the set this item will receive duty-free treatment under subheading 9801.00.10, HTSUS, assuming applicable documentation requirements are met.

HOLDING:

Classification

The wrapping paper gift bag and the gift bag ensemble are classifiable under subheading 4819.40.0040, HTSUS, dutiable at a rate of 5.3% ad valorem. The treasure chest (pre-wrapped) gift box, the laminated open-ended gift box (capable of folding ) and gift box ensemble, and the laminated pyramid box and gift box ensemble are classifiable under subheading 4819.20.0040, HTSUS, dutiable at a rate of 2.8% ad valorem. If the laminated open- ended box is not capable of folding, classification is under subheading 4819.50.4060, HTSUS, dutiable at a rate of 5.3% ad valorem. The bow tube, when imported with its contents of bows (made from plastic ribbon) and ribbon hanks, is classifiable under subheading 3926.40.00, HTSUS, dutiable at a rate of 5.2% ad valorem. The bow tube, when imported with its contents of bows (made from plastic ribbon) and ribbon hanks, is classifiable under subheading 3926.40.00, HTSUS, dutiable at a rate of 5.3% ad valorem. The 2-roll and 3-roll gift wrap ensembles cannot be classified because of insufficient information concerning the wrapping paper. The gift box tote cannot be classified because of insufficient information.

Eligibility for Duty-Free and Partial Duty-Free Treatment
a) 2-Roll and 3-Roll Gift Wrap Ensemble: The 2-roll and 3- roll gift wrap ensembles are not considered "products of" Mexico. Therefore, these articles are not eligible for duty-free treatment under the GSP. However, an allowance in duty under subheading 9802.00.80, HTSUS, will be permitted for the cost or value of the U.S.-origin components that have been assembled but not further fabricated abroad. The U.S.-origin components that are merely repackaged as part of the ensembles will be entered duty-free under subheading 9801.00.10 HTSUS, upon compliance with all documentation requirements.
b) Gift Bag: The gift bag is considered a product of Mexico; however, since the operations performed abroad do not result in a double substantial transformation, the cost or value of the exported materials may not be included in calculating the 35% value-content requirement under the GSP. The value requirement must be satisfied by direct processing costs alone. If the gift bag does not meet all of the requirements for receiving GSP treatment, an allowance in duty under subheading 9802.00.80, HTSUS, will be available for the cost or value of the U.S. fabricated rope handle, when imported with the gift bag. Items which are merely repackaged with the gift bag will be eligible for duty-free treatment under subheading 9801.00.10,

HTSUS, provided all documentation requirements are satisfied
c) Treasure Box: The treasure box is not considered to be a "product of" Mexico, and therefore is not eligible for duty- free treatment under the GSP. However, an allowance in duty under subheading 9802.00.80, HTSUS, will be permitted for the cost or value of the assembled U.S. components which have not been further fabricated abroad.
d) Laminated Gift Box: The laminated gift box is considered to be "product of " Mexico. However, the operations performed abroad do not result in a double substantial transformation of the U.S. exported materials. Therefore, the cost or value of these materials cannot be used in calculating the 35% value-content requirement under the GSP. The value requirement must be satisfied by direct processing costs alone. HTSUS subheading 9802.00.80 will not be applicable to the imported article since the exported components are subject to a process of fabrication in Mexico. Those U.S-origin items that are merely repackaged with the gift box will qualify for duty- free treatment under subheading 9801.00.10, HTSUS, assuming all documentation requirements are satisfied.
e) Laminated Pyramid Box: The pyramid box is considered to be a "product of" the BDC. However, since a double substantial transformation does not result from the operations in Mexico, the cost or value of the U.S. components will not be included in determining the 35% value-content requirement under the GSP. The value requirement must be satisfied by direct processing costs alone. An allowance in duty under HTSUS subheading 9802.00.80, will not be available since the U.S.-origin components used in creating this item are further fabricated in Mexico. Further, an assembly operation does not occur with respect to the U.S.-origin cording cut to length and manually placed in the box. However, the U.S. components merely repackaged with the gift box will qualify for duty-free treatment under subheading 9801.00.10, HTSUS, upon compliance with all documentation requirements.
f) Laminated Tote Box: Assuming GSP eligibility, this article is considered a "product of" Mexico. However, since a double substantial transformation does not occur, the cost or value of the U.S.-origin components cannot be counted in determining the value-content requirement under the GSP. The value requirement must be satisfied by direct processing costs alone. A duty allowance will not be allowed under HTSUS subheading 9802.00.80, for the cost or value of the U.S.-origin components that are further fabricated abroad. However, a partial duty exemption will be allowed under this provision for
the U.S.-origin assembled rope if merely cut to length and not further fabricated abroad.
g) Bow Tube/Candy Tube: Whether imported in bulk or as a set, this article is not considered to be "product of" the BDC. Therefore, it is not eligible for duty-free treatment under the GSP. However, a partial duty exemption will be allowed under HTSUS subheading 9802.00.80, for the cost or value of the U.S.- origin components that have not been further fabricated abroad. This will include the components comprising the bow, when imported as part of the bow tube set. The repackaged ribbon shanks will receive duty-free treatment under HTSUS subheading 9801.00.10, assuming applicable documentation requirements are satisfied.

Sincerely,

John Durant, Director
Commercial Rulings Division

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See also:

• Tariff No.: 3926.40.00 - Statuettes and other ornamental articles, of plastics
• Tariff No.: 4811.90.80 - Paper, paperboard, cellulose wadding and webs of cellulose fibers, nesoi, weighing over 30 g/m2, in certain size strips, rolls or sheets
• Tariff No.: 4819.20.00 - Folding cartons, boxes and cases of noncorrugated paper or paperboard
• Tariff No.: 4819.40.00 - Sacks and bags, nesi, including cones, of paper, paperboard, cellulose wadding or webs of cellulose fibers
• Tariff No.: 4819.50.40 - Packing containers, nesi, of paper, paperboard, cellulose wadding or webs of cellulose fibers
• Tariff No.: 9801.00.10 - U.S. goods returned without having been advanced in value or improved in condition while abroad
• Tariff No.: 9802.00.50 - Articles returned to the U.S. after having been exported for repairs or alterations, nesi
• Tariff No.: 9802.00.80 - U.S. articles assembled abroad, which have not lost their physical identity or have not advanced in value or improved in condition abroad