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HQ 084135

July 14, 1989

CLA-2 CO:R:C:G 084135 jlj 838512


TARIFF NO.: 4909.00.4020; 6111.20.6040

Mr. Robert M. Shreve
Mares-Shreve & Associates, Inc.
615 Second Avenue
Seattle, Washington 98104

RE: Tariff classification of a greeting card and a bib

Dear Mr. Shreve:

You requested a tariff classification for a greeting card and a bib imported from Hong Kong for your client, Gibson Greetings Inc. You submitted a sample along with your request.


The greeting card is made of paper. It is a New Baby congratulation card. The front of the card has an oval hole in it, through which the small attached baby bib is visible. The baby bib is made of a cotton terry material, with a plastic back and a woven cotton border.


How are the greeting card and the baby bib classified under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA)?


The greeting card is classified under the provision for printed or illustrated postcards, printed cards bearing personal greetings, messages or announcements, whether or not illustrated, with or without envelopes or trimmings: other: greeting cards, in subheading 4909.00.4020, HTSUSA, dutiable at the rate of 4.9 percent ad valorem.

The baby bib is classified under the provision for babies' garments and clothing accessories, knitted or crocheted: of cotton: other: other: other: other, in subheading 6111.20.6040, HTSUSA, dutiable at the rate of 8.6 percent ad valorem. We note that, under subheading 9902.57.20, duty has been suspended on babies' bibs for shipments imported on or before December 31, 1990. Textile category 239 applies to goods classified in this subheading.

Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relevant Section or Chapter Notes and, provided such headings or Notes do not otherwise require, according to the subsequent CRI's. There is no single heading which describes the card and bib combination.

GRI 3(b) provides for the classification of mixtures, composite goods, and goods put up in sets for retail sale. The card-bib combination is not a mixture or a composite good for tariff purposes, nor does it constitute "goods put up in sets for retail sale" as that term is defined by the Explanatory Notes to the Harmonized Commodity Description and Coding System. The Explanatory Notes, which constitute the official interpretation of the tariff at the international level, require that goods put up in sets for retail sale be put up together to meet a particular need or carry out a specific activity. In the absence of a particular need or specific activity common to both the card and the bib,they do not constitute a set classifiable in accordance with GRI 3(b). Consequently, the card and bib must be classified separately.


The greeting card and the baby bib are separately classified. The greeting card is classified in subheading 4909.00.4020, HTSUSA. The baby's bib is classified in subheadings 6111.20.6040 and 9902.57.20, HTSUSA.


John Durant, Director

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