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NY 885307

April 28, 1993

CLA-2-48:S:N8:234 885307


TARIFF NO.: 4821.10.2000; 9801.00.10

Tompkins & Davidson
One Astor Plaza
1515 Broadway, 43rd Floor
New York, N.Y. 10036

RE: The tariff classification of printed paper gift tags (labels) from Mexico; American Goods Returned; Packaging; Marking.


In your letter dated April 20, 1993, on behalf of your client, Cleo, Inc. (Memphis, Tennessee), you requested a tariff classification ruling.

A number of samples were submitted and are being returned as requested. They are various styles and sizes of "gift tags," i.e., slips of stiff paper which have been lithographically printed with colorful holiday motifs and the words "To" and "From," accompanied by spaces for the entry of names. Some of the tags have been further embellished with flock, glitter or stamping foil. Some incorporate adhesive strips or loops of yarn to facilitate attachment to gifts.

The applicable subheading for the gift tags manufactured in Mexico will be 4821.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for paper and paperboard labels of all kinds, printed in whole or in part by a lithographic process. The duty rate will be 8.8 cents per kilogram.

Articles classifiable under subheading 4821.10.2000, HTS, which are products of Mexico, are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

You also inquired about another scenario in which certain gift tags, fully printed/manufactured in the United States, will be sent to Mexico in bulk (either in individual pieces or loosely connected in the form of perforated sheets) merely to be packaged there and then returned to the U.S. for retail sale. (Your client contemplates doing this "prior to implementation of full Mexican production.") You state that "In Mexico, the tags will be separated, if necessary, and then packaged in blister packs (which will be comprised of U.S. origin materials, shipped in bulk and cut to finished dimensions in Mexico) in the same manner as the packaged samples enclosed herewith."

Upon compliance with the documentary requirements of 19 CFR 10.1, the applicable subheading for the U.S.-made gift tags imported from Mexico, after being blister-packed there using U.S. materials, will be 9801.00.10, HTS, which provides for products of the United States when returned after having been exported, without having been advanced in value or improved in condition by any process of manufacture or other means while abroad. The rate of duty will be free.

Finally, we agree with your contention that the U.S.-made gift tags, inasmuch as they constitute "American Goods Returned," need not be marked with their country of origin. Furthermore, we concur that your client's "distributor statement," which appears on the packaging and includes a U.S. address, does not trigger any special marking requirements in this situation.

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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