CLA-2 CO:R:C:T 952750 CMR
John W. Williams
Ely & Walker Co.
P.O. Box 1326
Lebanon, Tennessee 37087
RE: Country of origin of a country western style men's shirt;
19 CFR 12.130; country of origin textiles
Dear Mr. Williams:
This ruling is in response to your request of October 7,
1992, with regard to a country of origin determination on the
manufacture of a country western style shirt.
FACTS:
The manufacturing process of the subject shirt involves
cutting of Korean or Chinese fabric into garment parts in Korea.
The garment parts, along with snaps (from Japan), labels,
threads, buttons, collar stays and packaging material are then
sent to Myanmar. The garment is then assembled in Myanmar,
packaged and shipped to the United States.
ISSUE:
Is Korea or Myanmar the country of origin of the subject
shirt?
LAW AND ANALYSIS:
Country of origin rulings on textile articles are based upon
the language of Section 12.130 of Volume 19 of the Code of
Federal Regulations. Section 12.130 sets out the criteria in
determining the country of origin of textile goods. We are
attaching a recent ruling, HRL 951541 of July 1992. This ruling
involves the country of origin of a dress shirt and explains
section 12.130 in detail.
The country western style shirt in question is, in our view,
similar in construction and tailoring to a dress shirt. While
every country of origin ruling must be viewed according to -2-
the particular circumstances of the case, Customs has issued
rulings in the past which have stated that generally the complete
assembly of a dress shirt is viewed as a substantial
manufacturing process and is sufficient to confer origin. This
is based on the complexity of the assembly and the skill required
to produce a tailored dress shirt. As this garment is like a
dress shirt, the complete assembly of the garment in Myanmar
results in Myanmar being the country of origin.
The attached ruling, HRL 951541, involved three different
manufacturing schemes. Customs cannot advise you as to how to
structure your production process, but the attached ruling may be
helpful to you.
HOLDING:
Based on the information provided, the country of origin of
the subject shirt is Myanmar.
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
177.9(b)(1), Customs Regulations (19 CFR 177.9(b)(1)). This
section states that a ruling letter is issued on the assumption
that all of the information furnished in the ruling letter,
either directly, by reference, or by implication, is accurate and
complete in every material respect.
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, it is recommended that a new ruling
request be submitted in accordance with section 177.2, Customs
Regulations (19 CFR 177.2).
Sincerely,
John Durant, Director