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HQ 959671

September 20, 1996
CLA-2 RR:TC:TE 959671 jb


William J. LeClair
Trans-Border Customs Services, Inc.
P.O. Box 800
Champlain, NY 12919

RE: Country of origin determination for elastic braided belt; 19 CFR ?102.21(c)(2); tariff shift

Dear Mr. LeClair:

This is in reply to your letter, dated July 22, 1996, on behalf of your client, Accessories By Rae Inc., requesting a country of origin determination and the eligibility of this merchandise for duty free treatment under the North American Free Trade Agreement (NAFTA) for an elastic braided belt which will be imported into the United States. This letter will only address the proper country of origin for the subject merchandise; a determination under the NAFTA will be issued in a subsequent ruling.


The subject elastic braided belt, referenced style 1124, is made of braid in the piece. Cords of cotton with a rubber core have been braided together to form a textile fabric. The belt also features leather fittings and a brass buckle. As our New York office issued you New York Ruling Letter (NY) A85862, dated August 13, 1996, addressing the proper classification of this merchandise, this letter will only concern itself with the proper country of origin determination.

The manufacturing operations are as follows:


- webbing (made of 90 percent cotton fabric and 10 percent rubber material) is formed and sent to Canada in rolls.


- webbing is cut to length;
- leather fittings are added;
- buckle is added.


What is the country of origin of the subject merchandise?


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Section 334 of that Act (codified at 19 U.S.C. 3592) provides new rules of origin for textiles and apparel entered, or withdrawn from warehouse, for consumption, on and after July 1, 1996.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 (5) of Section 102.21.

Paragraph (c)(1) states that "The country of origin of a textile or apparel product is the single country, territory, or insular possession in which the good was wholly obtained or produced." As the subject merchandise is not wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section 102.21 is inapplicable.

Paragraph (c)(2) states that "Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or insular possession in which each foreign material incorporated in that good underwent an applicable change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of this section".

Paragraph (e) states that "The following rules shall apply for purposes of determining the country of origin of a textile or apparel product under paragraph (c)(2) of this section:"

6215-6217 If the good consists of two or more component parts, a change to an assembled good of heading 6215 through 6217 from unassembled components, provided that the change is the result of the good being wholly assembled in a single country, territory or insular possession.

The subject belt is classifiable in heading 6217, Harmonized Tariff Schedule of the United States (HTSUS). As the subject belt consists of multiple component parts (textile material, leather fittings and brass buckle) which are assembled in a single country into a finished textile belt, the country of origin of the belt is the single country where that assembly occurs, that is, Canada. See also, HQ 959027, dated April 5, 1995 (sic), wherein country of origin was conferred in the country of assembly.


The country of origin of the subject belt, referenced style number 1124, is Canada.

The holding set forth above applies only to the specific factual situation and merchandise identified in the ruling request. This position is clearly set forth in section 19 CFR 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

Should it be subsequently determined that the information furnished is not complete and does not comply with 19 CFR 177.9(b)(1), the ruling will be subject to modification or revocation. In the event there is a change in the facts previously furnished, this may affect the determination of country of origin. Accordingly, if there is any change in the facts submitted to Customs, it is recommended that a new ruling request be submitted in accordance with 19 CFR 177.2.


John Durant, Director

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