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NY B85018

June 11, 1997

CLA-2-61:RR:NC:WA:361 B85018


TARIFF NO.: 6204.61.9010

Mr. Dennis Minieri
KCNY, Inc.
485 7th Avenue Rm 905
New York, NY 10018

RE: Classification and country of origin determination for a pair of woman's woven wool trousers; 19 CFR 102.21(c)(2); tariff shift

Dear Mr. Minieri:

This is in reply to your letter dated May 23, 1997, requesting a classification and country of origin determination for a pair of woman's woven wool trousers which will be imported into the United States. As requested, your sample will be returned.


The subject merchandise consists of a pair of woman's woven trousers constructed from 100 percent wool fabric with a 100% woven polyester lining. The garment features fly front opening with zipper and one button closure, five belt loops, and two side seam and one rear pockets.

The manufacturing operations for the trousers are as follows:

The fabric is cut in the Philippines, then sewn into completed trousers. Completed garments are returned to China for washing, detail finishing (loose threads trimming) and final packing, then shipped to the United States.


What is the classification of the denim style trousers?

What is the country of origin, and from what country is quota status derived on the subject merchandise?


The applicable subheading for the trousers will be 6204.61.9010, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for women's or girls'...trousers...: of wool: other: trousers and breeches: women's. The rate of duty will be 16 percent ad valorem.

The trousers fall within textile category designation 448. The designated textile and apparel categories may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes. To obtain the most current information available, we suggest that you check, close to the time of shipment, the Status Report on Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.


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Section 334 of that Act (codified at 19 U.S.C. 3592) provides new rules of origin for textiles and apparel entered, or withdrawn from warehouse, for consumption, on and after July 1, 1996.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 of the foreign materials 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) in pertinent part 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":

HTSUS Tariff shift and/or other requirements

6201 - 6208 (1) If the good consists of two or more component parts, a change to an assembled good of heading 6201 through 6208 from unassembled components, provided that the change is the result of the good being wholly assembled in a single country, territory, or insular possession.

As the trousers are assembled in a single country, that is, the Philippines, as per the terms of the tariff shift requirement, country of origin is conferred in the Philippines.


The country of origin of the trousers is the Philippines. Based upon international textile trade agreements products of the Philippines are subject to quota and the requirement of a visa.

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 sections states that a ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). 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.

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Angela De Gaetano at 212-466-5540.


Paul K. Schwartz

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