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UNITED STATES GOVERNMENT DEPARTMENT OF THE TREASURY Memorandum UNITED STATES CUSTOMS SERVICE

DATE: June 27, 1995
FILE: CLA-2-98:S:N:N1:810881-101

TO: DIRECTOR, OFFICE OF REGULATIONS AND RULINGS HEADQUARTERS, U.S. CUSTOMS SERVICE

FROM: CHIEF, MACHINERY BRANCH
NEW YORK SEAPORT

SUBJECT: APPLICABILITY OF HEADING 9802.00.8065 TO FABRICATION OF AUTOMOTIVE SEAT BELTS.

We have reviewed NY Ruling 810881 from Mr. Jack Alsup of Alsup & Alsup, Inc. P.O. Box 1251, Del Rio Texas, 78841 regarding the applicability of Heading 9802.00.8065 to fabrication of seat belts in Mexico.

The inquirer, on behalf of their client, Gateway Safety Systems, a Division of Takata, Inc., P.O. box 420459, Del Rio, Tx., requests information as to the applicability of Heading 9802.00.8065 to the assembly process described below.

The 100 percent nylon webbing is made in the United States. It is exported to Mexico in 183 meter rolls. The rolls of webbing are cut in one dimension only, to approximately 3 meter lengths, at a slightly curved angle. The curved cut is made to facilitate the assembly and eliminate the necessity of trimming the corners to prevent their snagging during use. The webbing is sewn onto a buckle on one end and the other end is sewn around a pin which will be inserted into the retract mechanism. Numerous other parts are assembled together to produce the finished seat belt assembly.

We refer to HQ Ruling 554961 and many other correlative rulings which address cutting and sewing as operations incident to assembly. We offer that no further fabrications outside the boundaries of operations incident to assembly exist.

We, therefore, agree with the inquirer that, in this case as described, the applicability of Heading 9802.00.8065 be approved.

If you have any further questions regarding this matter, please contact NIS Robert DeSoucey at 212-466-5667. Please send a copy of your reply to this office.

Robert Slomovitz


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