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NY C81189

November 17, 1997

CLA-2-RR:NC:WA:353 C81189


Mr. Stephen M. Zelman
888 Seventh Avenue
New York, New York 10106

RE: Classification and country of origin determination for men's neckties; 19 CFR 102.21(c)(3)

Dear Mr. Zelman:

This is in reply to your letter dated October 22, 1997, requesting a classification and country of origin determination for men's neckties which will be imported into the United States.


The subject merchandise consists of Men's neckties.

The manufacturing operations for the Men's neckties are as follows:

In China
Silk greige goods are woven from chinese silk yarn which will ultimately form the outer shell of the necktie

In South Korea
Silk fabric is dyed

In Italy
Silk fabric is cut to shape
Other fabric components of an-made fibers are woven and cut to shape to form the interlining and "tipping"(the inside shell of the necktie) Neckties are wholly assembled by sewing the cut to shape fabric components together, folding, attaching a label, steaming and pressing to form a permanent crease.


What is the classification and country of origin of the subject merchandise?


Classification of goods under the HTSUSA is governed by the General Rules of Interpretation (GRIS). GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Merchandise that cannot be classified in accordance with GRI 1 is to be classified in accordance with subsequent GRI's taken in order.

Heading 6215, HTSUSA, is the provision for ties, bow ties and cravats. As the subject ties fit squarely within this heading, they are classifiable under Heading 6215, HTSUSA.


On December 8, 1994, the President signed into law the Uruguay Round Agreements Act. Section 334 of that Act provides new rules of origin for textiles and apparel entered, or withdrawn from warehouse, for consumption, on and after July 1, 1996.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 (1) 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 the change is the result of the good being wholly assembled in a single country, territory, or insular possession.

Section 102.21(b)(6) defines wholly assembled as :

The term "wholly assembled" when used with reference to a good means that all components, of which there must be at least two, preexisted in essentially the same condition as found in the finished good and were combined to form the finished good in a single country, territory, or insular possession. Minor attachments and minor embellishments (for example, appliques, beads, spangles, embroidery, buttons) not appreciably affecting the identity of the good, and minor subassemblies (for example, collars, cuffs, plackets, pockets), will not affect the status of a good as "wholly assembled" in a single country, territory, or insular possession.

The subject necktie components preexisted in the same condition as found in the finished good and were wholly assembled in Italy which will be the country of origin.


The country of origin of the necktie is Italy. Based upon international textile trade agreements products of Italy are not presently 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 Martin Weiss at 212-466-5881.


Robert B. Swierupski

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