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NY B84430

May 9, 1997

CLA-2-46:RR:NC:SP:230 B84430


TARIFF NO.: 4602.90.0000

Ms. Judy Kearney
Network Brokers International, Inc.
Airport Industrial Office Park, Bldg. C-1D 145th Ave. & Hook Creek Blvd.
Valley Stream, N.Y. 11581

RE: The tariff classification of decorative "wraphia bows," made of rayon strips, from China.

Dear Ms. Kearney:

In your letter dated April 16, 1997, on behalf of Berwick Industries, Inc. (Berwick, PA), you requested a tariff classification ruling.

A sample was submitted and will be retained for reference. It is a retail display card holding six identical items described as "wraphia bows." Each bow consists of several strips of rayon which have been bundled together, tied into a bow formation and knotted in the center. The individual strips, which have an apparent width slightly over 5 mm, seem to have been longitudinally creped, crinkled or similarly processed from much wider (about 35 mm) strips, prior to bow formation.

The bows have an overall length of about 18 inches, and are said to be intended for holiday decorating applications. They are offered in three colors: "Imperial Red" (#T3600), "Oatmeal" (#T3610) and "Burgundy" (#T3620).

The applicable subheading for the "wraphia bows" will be 4602.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other (non-enumerated) articles made directly to shape from plaiting materials. The rate of duty will be 4.2%. Articles classifiable under this subheading are not currently subject to quota or visa requirements.

You also asked about country of origin marking requirements, given the following facts:

The rayon "wraphia" is made in Japan and put up on spools of 100 yards, and sent to China. In China, the manufacturer will cut the ribbon to length, tie it into a bow formation and knot it in the center. Six bows will then be put up on cards, packed into a larger carton and exported to the USA.

We find that in this scenario the Japanese "wraphia" ribbon undergoes a substantial transformation in China, meaning that the finished bows will be considered products of China. Accordingly, the retail display cards are required to be marked with a phrase such as "Made in China," legibly and in a conspicuous place. If a U.S. address also is shown on the card, the country of origin marking must appear in close proximity to said address, in lettering of comparable size.

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

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 Paul Garretto at 212-466-5779.


Gwenn Klein Kirschner

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