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NY C86901

April 22, 1998

MAR-2 RR:NC:SP:233 C86901


Mr. Karl F. Krueger
AEI-Carr Customs Brokerage Services
1600 West Lafayette
Detroit, MI 48216


Dear Mr. Krueger:

This is in response to your letter dated April 2, 1998, on behalf of your client Krug Inc., regarding ruling NY C85099 issued to you on March 18, 1998. The ruling concerned the country of origin marking requirements for imported chairs which are assembled from components from Germany and Italy in a NAFTA country. You point out the fact that the upholstery used in the manufacture of the chairs is entirely of Canadian origin and have enclosed a copy of the costing summaries.

In ruling NY C85099 we indicated that the chairs were to be marked "Assembled in Canada of Italian and German components". Inasmuch as the upholstery is of Canadian origin, the Italian and German chair parts do not undergo the applicable change in tariff classification as set out in 19 C.F.R. section 102.20. Accordingly, the countries of origin of the chairs is Italy, Germany and Canada, and the chairs must be marked "Assembled in Canada of Italian, German and Canadian components".

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 Lawrence Mushinske at 212-466-5739.


Robert B. Swierupski, Director

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