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NY 891520

November 23, 1993

CLA-2-96:S:N:N6:343 891520


TARIFF NO.: 9606.22.0000

Mr. Miguel Ruiz
Miami International Forwarders
P.O. Box 523730
Miami, FL 33152-3730

RE: The tariff classification of button covers from Guatemala.

Dear Mr. Ruiz:

In your letter dated October 20,1993, on behalf of Bel Air Tool Corp., you requested a classification ruling.

You have submitted a sample of six button covers on a card. The card states "An Official Looney Tunes Product, Button Covers." Each of the six button covers represents a cartoon character.

You state that the button covers are made of zinc and are painted with epoxy. You also state that they are 100% USA materials. You do not state, however, the processing that has been done in Guatemala.

The applicable subheading for the button covers will be 9606.22.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for button...of base metal, not covered with textile. The duty rate will be 3.6 percent ad valorem.

Articles classifiable under subheading 9606.22.0000, HTS, which are products of Guatemala are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

You also ask about the marking of this item. We presume that the button covers will be imported like the sample, six button covers to a card. Since the button covers appear to be sold to the ultimate consumer on the card to which they are attached, the front of the card should be marked with the country (Made in Guatemala).

The back of the card contains the name of the trademark owner. No geographical designation appears on the back of the card (i.e. USA). The country of origin, therefore, does not have to be placed on the back of the card.

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

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