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HQ 959564

November 4, 1996
CLA-2 RR:TC:TE 959564 jb


Mr. Man
Saleton Industry Ltd.
Shing King Ind. Bldg.
Flat A-B, 2nd Floor
45 Kut Shing Street
Chai Wan, Hong Kong

RE: Country of origin determination; Section 102.21, Customs Regulations; information letter

Dear Mr. Man:

This is in reply to your letter dated July 22, 1996, requesting a country of origin determination for knit and woven gloves which will be imported into the United States. Samples were submitted to this office for examination.

In your letter you state the following manufacturing operations for the subject gloves:

Knit Gloves

MACAU Unspecified Country

- knitting; - sewing finger tips;
- inspection; - sewing lining
- sewing label; - turn cuff.
- sewing tag;
- finishing and packing.

Woven Gloves

MACAU Unspecified Country

- assembly; - cutting;
- sewing wrist; - sewing finger tips;
- sewing label; - printing or embroidery.
- inspection;
- turning glove;
- sewing tag;
- finishing and packing.

On December 8, 1994, the President signed into law the Uruguay Round Agreements Act. Section 334 of that Act (codified at 19 U.S.C. 3592) provides new rules of origin for textiles and apparel entered, or withdrawn from warehouse, for consumption, on and after July 1, 1996. On September 5, 1995, Customs published Section 102.21, Customs Regulations, in the Federal Register, implementing Section 334 (60 FR 46188). Thus, effective July 1, 1996, the country of origin of a textile or apparel product shall be determined by sequential application of the general rules set forth in paragraphs (c)(1) through (c)(5) of Section 102.21.

The manufacturing operations you have presented to this office are not sufficiently detailed for Customs to issue a binding country of origin determination. In order for Customs to issue a proper determination, the following additional information is required:

1. an explanation of what is meant by "assembly" (what those processes involve);
2. in those cases where the gloves feature a PVC patch or a lining, you should indicate where the PVC patch is sourced, or in the case of the lining, where the lining is made before being assembled to the glove;
3. in regard to the knit gloves, although several samples were provided to us, each was representative of a different manufacturing process and we were not able to determine if and/or when the gloves were knit to shape; you should indicate as such.

Accordingly, until this information is provided to us, we will not be able to issue you a binding ruling.


John Durant, Director

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