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NY 865246

August 13, 1991

CLA-2-42:S:N:N3G:341 865246


TARIFF NO.: 4202.32.2000

Mr. Marc S. Greenberg
Vice President
American Shipping Company
600 Sylvan Avenue
P.O. Box 1486
Englewood Cliffs, N.J. 07632

RE: The tariff classification and country of origin marking of a coin purse from China

Dear Mr Greenberg:

In your letter dated July 17, 1991, you requested a ruling as to the proper country of origin marking for a coin purse imported in bulk. Your request is on behalf of Topline Products Co. Inc.

A sample of a Polyvinyl Chloride (PVC) coin purse has been submitted. The item is a coin purse and is manufactured by cutting PVC sheeting material to shape and heat sealing the edges. It is closed by means of a base metal snap frame which is crimped to the top edge of the purse. The sample is packed in a blister pack with a lip gloss. The reverse side of the blister pack is printed with various literature and information including the legend "Change Purse made in China. All else made in USA." The origin information appears immediately above and in comparable print as the United States name and address of the distributor.

The applicable subheading for the coin purse will be 4202.32.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for articles normally carried in the pocket or in the handbag, with outer surface of plastic sheeting, other. The duty rate will be 20 percent ad valorem.

You have indicated that, due to the heat sealing process, the item cannot be permanently and conspicuously marked with the country of origin as provided by Section 304, Tariff Act 1930, as amended. In addition, you have indicated that the blister pack marking would be sufficient to comply within the marking requirements.

If imported in bulk and it is to be repacked in the United States, the purse would be subject to Customs Regulation 134.26 which provides for imported articles repacked or manipulated. A copy of the regulation is enclosed with this reply. This office would accept the sample marking as satisfying the regulation.

In the absence of regulation compliance, each purse must be properly marked with the country of origin. It is recommended that a legible label be placed in a conspicuous location along the interior top portion and affixed to the purse in the same manufacturing process as when the frame is crimped.

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

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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