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HQ 956987

March 2, 1995

CLA-2: CO:R:C:T 956987 PR


Mr. Roger Lew
Janeve Sport Inc.
13837 Magnolia Ave.
Chino, California 91710

RE: Country of origin of four garments; components cut in Taiwan and assembled in China

Dear Mr. Lew:

This is in reply to your letter of July 19, 1994, concerning the country of origin of four garments. Our ruling on the matter follows.


Four finished apparel samples were submitted along with samples of the cut panels which, when assembled, form those samples. The garments are not labeled or tagged. However, we have identified their style numbers based on the descriptions contained in the inquiry. All the garments are stated to be intended for wear by women and all are constructed from fabric that is 65 percent polyester and 35 percent cotton.

Style 3102 is a knit long sleeve cardigan with ribbed cuffs and waistband. Style 3041 is a knit long sleeve pullover. Style 3129 is a pair of knit pants with an elastic waistband and Style 3163 is a pair of knit shorts with a ribbed waist.

In Taiwan, the garments are designed and the fabric is knit, dyed, and cut into garment parts. The garment parts are sent to China where they are assembled by sewing, finished, and packaged for export to the United States. According to very brief submitted cost breakdowns, significantly larger percentages of the costs to produce the subject garments are incurred in Taiwan.


The issue presented is which country, Taiwan or China, is the country of origin of the sample garments.


Section 12.130, Customs Regulations (19 CFR 12.130) provides, in pertinent part, that a textile or textile product which consists of materials processed in more than one foreign country shall be a product of the country where it last underwent a substantial transformation. A textile or textile product will be considered to have undergone a substantial transformation if it has been transformed by means of substantial manufacturing or processing operations into a new and different article of commerce.

In this regard, the assembly in China of the knit components does not meet the criterion of a substantial manufacturing or processing operations. Customs has ruled on similar merchandise on numerous occasions. For example, see Headquarters Ruling (HQ) 088235, dated March 15, 1991; HQ 950132, dated December 4, 1991; and HQ 953488, dated May 14, 1993.


The country of origin of the subject goods is Taiwan.

Section 177.9(b)(1), Customs Regulations (19 CFR 177.9 (b)(1), states that a ruling is issued on the assumption that all of the information furnished in connection with the ruling request and incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

Accordingly, the holding set forth above applies only to the specific factual situation and the merchandise identified in the ruling request. Should it subsequently be determined that the information furnished is not complete or does not comply with 19 CFR 177.9(b)(1), the ruling will be subject to modification or revocation. -3-

If there is a change in the facts furnished, the holding in this ruling may be affected. In such an event, it is recommended that a new ruling request be submitted in accordance with Section 177.2, Customs Regulations (19 CFR 177.2).


John Durant, Director

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