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NY B80190




December 9, 1996

CLA-2-61:RR:NC:BCH 3:353 B80190

CATEGORY: CLASSIFICATION

TARIFF NO.: 6117.90.9080; 6117.90.9090

Mr. William Poetter
Outer Banks
P.O. Box 1330
2118 Mercantile Drive NE
Leland, North Carolina 28451

RE: The tariff classification of collars and cuffs from Honduras

Dear Mr. Poetter:

In your letter dated October 17, 1996, received in our office on December 6, 1996, you requested a tariff classification ruling for a "collar and separation" operation in Honduras. NY Ruling 813955, dated September 6, 1995 was issued to you on the same operation except that it took place in Costa Rica.

As stated in NY 813955, the same operation whereby rolls of knitted fabric of 100% cotton or 50/50 cotton & man-made fiber blend with a separating thread making lines of demarcation for collars and cuffs, manufactured in the United States, will be sent to Honduras for separation. The collars and cuffs are said to be separated by means of clipping one end of the thread and pulling it through to separate the collars and cuffs. The resultant products imported in the United States will be collars and cuffs.

The applicable subheading for the knit 50/50 cotton & man-made fiber blend collars and cuffs will be 6117.90.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for other "Other made up clothing accessories, knitted or crocheted; knitted or crocheted parts of garments or of clothing accessories: Parts: Other... Other: Of man-made fibers.". The rate of duty will be 15.3 percent ad valorem.

The applicable subheading for the knit 100% cotton collars and cuffs will be 6117.90.8090, Harmonized Tariff Schedule of the United States (HTS), which provides for "Other made up clothing accessories, knitted or crocheted; knitted or crocheted parts of garments or of clothing accessories: Parts: Other... Other: Of cotton. The rate of duty will be 15.3 per cent ad valorem.

The 100% cotton collars and cuffs fall within textile category designation 359 and the 50/50 cotton & man-made blend collars and cuffs fall within textile category designation 659. Based upon international textile trade agreements, products of Honduras are not subject to quota or visa requirements.

These items may qualify for subheading 9802.00.5060, Harmonized Tariff of the United States (HTS), which provides for "Articles returned to the United States after having been exported to be advanced in value or improved in condition by any process of manufacture or other means: Articles exported for repairs or alterations: Other.... Other: Other." upon compliance with all applicable regulations. The duty will be based upon the value of the repairs or alterations.

If you elect to have this identical operation performed in Mexico, the duty on the value of the repair or alteration would be free.

You supplied samples of your existing "care/content" labels which we understand will be appropriately affixed to garments that will be manufactured in the United States that will incorporate the collars and cuffs that have undergone the separation process in Honduras. You stated that in earlier discussions with Customs personnel that the process of separation would not have any effect on your current labels. It is our opinion that the labels as constituted are sufficient. However, be advised that the use of the legend "Made in USA" on textile products is governed by the Textile Fiber Products Identification Act (15 U.S.C), which is administered by the Federal Trade Commission (FTC). Since Customs does not issue rulings or decisions interprerting FTC guidelines, we suggest that you contact the FTC, 6th and Pennsylvania, NW, Washington, D.C. 20580, for information regarding the propriety of the proposed legend.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Martin Weiss at 212-466-5881.

Sincerely,

Roger J. Silvestri
Director

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