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NY 801515

Sept. 14, 1994

CLA-2-61:S:N:N5:361 801515


Ms. Gail T. Cumins
Sharretts, Paley, Carter & Blauvelt, P.C. 67 Broad Street
New York, N. Y. 10004

RE: The country of origin of women's knit sleepwear made in Israel and Sri Lanka.

Dear Ms. Cumins:

In your letter dated August 24, 1994, on behalf of Ventura Enterprises Co., you requested a country of origin determination for various knit garment. The samples are being returned to you, as you requested.

Five styles of women's knit nightgowns have been submitted. Since they have no style numbers, they have been designated with letters A-E. All of the garments are made from 100% cotton knit fabric. Style A is a short sleeve, V-neck, mid-calf length nightgown with lace trim; style B is a short sleeve V-neck, mid- calf length nightgown with a two button placket; style C is a long sleeve, mid-calf length nightgown with a rounded scalloped collar, five button placket and four rows of tucking on each side; style D is a long sleeve, knee-length nightgown with a stand up collar, four button scalloped placket and lace trim; style E is a long sleeve, mid-calf length nightgown with a ribbon laced through the placket.

The garment is made in both Israel and Sri Lanka. The fabric is cut into the appropriate pattern parts in Israel. The bolts of cloth from which the pattern parts are cut are not marked with the pattern prior to importation in Israel. The parts are sewn together and the garment is finished in Sri Lanka. Cutting the fabric to pattern is a substantial transformation, changing fabric into garment parts. The mere attaching of those parts is not considered a substantial transformation, therefore, the country of origin of the blouse is Israel.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is entered. 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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