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NY 879419

October 23, 1992

CLA-2-49:S:N1:234 879419


TARIFF NO.: 4906.00.0000

Mr. Theodore E. Theodorsen
56 Old Ox Road
Manhasset, N.Y. 11030

RE: The tariff classification of handwritten solicitation letters, with envelopes, from Jamaica.

Dear Mr. Theodorsen:

In your letter dated October 14, 1992, you requested a tariff classification ruling.

You plan to send to Jamaica letterhead paper and letterhead envelopes. You state that "these would be from various organizations who contract us to write handwritten solicitation letters on their behalf." After the letters are written and the envelopes are addressed in Jamaica, they will be shipped back to New York, where you will affix U.S. postage.

You suggest that this operation might fall under the "807 law," i.e., the tariff provision for articles assembled abroad from fabricated U.S. components. In our judgment, however, such tariff treatment for your proposed transaction would not be appropriate.

The applicable subheading for the handwritten letters, with their addressed envelopes, will be 4906.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for handwritten texts. The rate of duty will be free. (It is assumed that all of the letters will be individually handwritten; this ruling will not apply to mechanical or photomechanical reproductions.)

With regard to your question on the proper valuation, for Customs purposes, of the imported product, we believe it would be the sum of: a) the cost of the paper and envelopes, b) the cost of transporting same to the Jamaican worksite, and c) the charge for (or cost of) the work done in Jamaica. (This is advisory only, and should not be construed as a "value ruling.")

The classification portion of 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

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