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NY 810383

June 7, 1995

MAR-2-61:S:N:N5:361 810383


Mr. Kevin Maher
C Air Custom House Brokers-Forwarders, Inc. 153-66 Rockaway Blvd.
Jamaica, New York 11434

RE: The Country of Origin Marking and Classification of pair of women's woven trousers.

Dear Mr. Maher:

This is in response to your letter dated May 11, 1995, on behalf of Cygne Design, requesting a classification and marking ruling of a pair of woman's trousers that will be manufactured under various scenarios. A sample of the cut components and completed garment was submitted with your letter for review, and will be returned, as you requested.

The garment, style L8611, is a pair of woman's 100% woven wool trousers, fully lined with 100% acetate woven fabric. The trousers feature a waistband with five belt loops, a zipper and single button front closure, pleats, and cuffs.

Style L8611 will be classified under subheading 6204.61.9010, Harmonized Tariff Schedule of the United States (HTS), which provides for women's trousers, of wool. The rate of duty will be 16.7 percent ad valorem.

Style L8611 falls within textile category designation 448. Based upon international textile trade agreements, products of **Guatemala are subject to a visa requirement and quota restraints.

The designated textile and apparel category may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Since part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes, to obtain the most current information available, we suggest that you check, close to the time of shipment, the Status Report On Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.

You have indicated that these trousers may be manufactured in one of the two ways mentioned, specifically:

The trousers will be cut in the U.S. and sewn in Guatemala.

The garments will be cut in an unnamed European country and sewn in Guatemala.

As you noted, in the first instance, the correct marking for the garment is "made in Guatemala of U.S. components. A visa from Guatemala is required, and the merchandise will be subject to quota restraints.

In the second instance, the garment will be cut in a European country and sewn in Guatemala. For trousers, cutting the fabric to pattern is a substantial transformation, changing fabric into garment parts. The simple attaching of those parts is not considered a substantial transformation, therefore, the country of origin of the trousers is the unnamed European country. The garment should, therefore, be marked "made in {name of specific country}." You also asked whether the country in which the lining is cut would make a difference to the country of origin of the goods. It would not. The trousers may also be subject to visa requirements and quota restraints, depending on the European country in which they are cut.

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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