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January 4, 1999

CLA-2-39:RR:NC:3:353 D85940


TARIFF NO.: 3926.20.9010, 3926.20.9050

Mr. Ulrich Henssge
European Dynamics International
P.O. Box 464027
Lawrenceville, GA 30042

RE: The tariff classification and status under the North American Free Trade Agreement (NAFTA), of a vinyl apron and bib from Mexico; Article 509

Dear Mr. Henssge:

In your letter dated December 14, 1998 you requested a ruling on the status of a vinyl apron and bib from Mexico under the NAFTA.

The classification of the vinyl apron and bib was addressed in ruling NY D80047. The vinyl apron was classified under 3926.20.9010 and the vinyl bib was classified under 3926.20.9050.

You state that all the material used to make either item is of Mexican origin; we will assume for purposes of this ruling that the vinyl material was made from foreign raw materials, and became “originating” material in the process of being transformed into vinyl in Mexico. You also state that all the cutting and sewing to make the finished product is performed in Mexico.

The vinyl apron and bib, being made entirely in the territory of Mexico using materials which themselves were originating, will satisfy the requirements of HTSUSA General Note 12(b)(iii). The merchandise will therefore be entitled to a free rate of duty under the NAFTA upon compliance with all applicable laws, regulations, and agreements.

This ruling is being issued under the provisions of Part 181 of the Customs Regulations (19 C.F.R. 181). This ruling letter is binding only as to the party to whom it is issued and may be relied on only by that party.

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 Kenneth Reidlinger at 212-466-5881.


Robert B. Swierupski

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