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March 29, 1999

MAR-2-48:RR:NC:2:234 D89713


Ms. Eleanore Kelly-Kobayashi
Rode & Qualey, Attorneys at Law
295 Madison Avenue
New York, N.Y. 10017

RE: Country of origin of certain paper-board boxes; substantial transformation

Dear Ms. Kelly-Kobayashi:

In your letter dated March 23, 1999, on behalf of your client, CDE Cartondruck - Embadac U.S.A., Summit, New Jersey, (“CDE”), you requested a ruling on the country of origin of certain folding cartons imported from Switzerland. A sample carton, and a sample printed sheet of paperboard, were submitted for review; these will be retained for reference.

CDE will be importing folding cartons classifiable in subheading 4819.20.00, HTSUS, for use mainly by cosmetic and fragrance companies. The company plans to purchase paperboard from Sweden or Finland which will be imported into Germany. In Germany the sheets of paperboard, which measure approximately 26 inches by 40 inches will be printed.

The printed paperboard sheets will then be sent to Switzerland where they will be die cut into individual blanks and glued, thus transforming the paperboard sheets into folding cartons. In some cases additional text will be hot stamped and/or embossed to the cartons. The finished cartons will then be packed, labeled and exported to the United States.

You assert that, pursuant to 19 C.F.R. 134.1(b), the country of origin of these boxes will be Switzerland, inasmuch as the printed sheets of paperboard from Germany will have undergone a substantial transformation in Switzerland under the terms of United States v. Gibson-Thomsen Co., 27 CCPA 267, 270 (1940).

We agree. The country of origin of imported paperboard boxes, manufactured and imported into the United States under these circumstances, is Switzerland.

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

A copy of this ruling letter 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 this ruling, contact National Import Specialist Carl Abramowitz, at (212) 637-7060. Sincerely,

Robert B. Swierupski

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