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HQ 555009

July 2, 1988

CLA-2 CO:R:C:V 555009 DBI


TARIFF NO.: 9802.00.80; 807.00

Mr. Roberto Ganza-Gongora
J.O. Alvarez, Inc.
#1 Ramos Road
P.O. Box 1434
Laredo, Texas 78042-1434

RE: Applicability of partial duty exemption of item 807.00, TSUS, to certain outdoor extension cords to be assembled in Mexico

Dear Mr. Garza-Gongora:

This is in response to your letter dated April 21, 1988, in which you request a ruling concerning the applicability of item 807.00, Tariff Schedules of the United States (TSUS), to certain outdoor extension cords to be assembled in Mexico and imported by your client.


You advise that the raw material used in the assembly include U.S.-made stranded copper wire, paper, paper filler, male and female plugs, Underwriters Laboratories (U.L.) label and package material. The tie or band used is Mexican and the polyvinyl chloride (PVC) will be U.S.-made or Mexican. You indicate that the following operations will be performed abroad:

1. The stranded copper wire will be covered with PVC.

2. Three different colored wires will be bunched and twisted together with papers and filler to form a cable.

3. The cable will be covered with PVC and the serving paper.

4. The cable will then be cut to its required length of 8 to 110 feet.

5. The ends of the cable will be stripped for crimping into place the male or female blades.

6. The blades will be molded in place by covering them with PVC.

7. The finished cord will be tested with High Voltage Continuity, Polarity and Circuit Short Test as required under the U.L. procedures.

8. The cord set will be later prepared for application of the Sleeves.

9. Lastly, the cord sets will be packed into the cartons, palletized and covered with PVC film for shipping.


Whether the described outdoor extension cords, when returned to the U.S., will be eligible for the partial exemption from duty in item 807.00, TSUS (9802.00.80, Harmonized Tariff Schedule of the United States (HTSUS))?


Item 807.00, TSUS, applies to articles assembled abroad in whole or in part of fabricated components, the products of the U.S., with no operations performed thereon except the attachment of the components to form the imported merchandise and operations incidental thereto. An article classified under item 807.00, TSUS, is subject to duty upon the full appraised value of the imported article, less the cost or value of such products of the U.S.

We have previously held in a ruling dated June 25, 1987 (HQ 554577), that covering telephone line cords and coiled cords with PVC was a fabrication or non-assembly step, and, as such, precluded application of item 807.00, TSUS. We stated that in this type of coating process, there was no joinder of separate solid components. See HQ ruling letter 554416 dated March 6, 1987.

In the present case, there are many operations being performed abroad in order to construct the finished extension cord. The wire is initially covered with PVC, and then covered again after the wires are cabled. After the cables are stripped for crimping the blades into place, the blades are also covered with PVC. Based on our previous ruling, this coating operation would not be an acceptable assembly operation within the meaning of item 807.00, TSUS. Since the coating of the wires, cables and blades are integral to the construction of the finished extension cord, it would be impossible to separate out the individual steps of the assembly, which alone might be acceptable assembly, and
still construct a finished extension cord. Therefore, the operations performed abroad, taken as a whole, do not constitute an acceptable assembly under item 807.00, TSUS.


On the basis of the information submitted, we are of the opinion that the operations performed abroad may not be considered an acceptable assembly, and, therefore, no allowances in duty may be made under item 807.00, TSUS.


John Durant, Director

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