CLA-2 OT:RR:CTF:TCM H217616 LWF
Edmund Yan
ClearFreight, Inc.
880 Apollo Street, Suite 101
El Segundo, CA 90245
RE: Revocation of NY N131398, dated November 19, 2010; classification of dolomite ceramic novelty drinking vessels from China
This letter pertains to New York Ruling Letter (“NY”) N131398, dated November 19, 2010, concerning the classification under the Harmonized Tariff Schedule of the United States (HTSUS) of two dolomite ceramic novelty drinking vessels imported by your client, Progressive Specialty Glass Company, Inc. (“Progressive”). We have reviewed NY N131398 and find the ruling letter to be in error. In reaching our decision, we considered the arguments raised in Progressive’s submission, dated December 21, 2011, requesting reconsideration of NY N131398. For the reasons set forth below, we hereby revoke NY N131398.
Pursuant to section 625(c)(1), Tariff Act of 1930 (19 U.S.C. §1625(c)(1)), as amended by section 623 of Title VI, notice proposing to revoke Ruling Letter NY N131398, dated November 19, 2010, was published on July 23, 2014, in Volume 48, Number 29, of the Customs Bulletin and Decisions. No comments were received in response to the Notice.
FACTS:
In NY N131398, CBP described the merchandise at issue (the “Drinking Vessels”), as follows:
[The Drinking Vessels] consist of two dolomite ceramic novelty drinking vessels. The first item is identified as the “Paris Balloon.” The item is in the shape of a hot air balloon. The upper portion of the item is spherical in shape, representing the balloon, and measures 4½ inches in diameter. It has a removable lid that incorporates a hole for placement of a straw (not included). The balloon is colored blue with the word “Paris” in raised white letters, which is repeated four times around the balloon. The balloon sits on a square-shaped base, representing the basket, which measures approximately 3 inches square by 2 inches in height. The base is colored black, with a raised depiction of the Eiffel Tower surrounded by fireworks, with the word “Paris” in raised, white letters, and the words, “LAS VEGAS” below it in raised, red letters. The depiction is repeated on all four sides of the base. The article measures approximately 8 inches in height overall.
The second item is identified as the “Med Times Knights Head Gold” and is in the shape of an armored knight’s head, including the neck, chest and shoulders. The item is colored metallic gold and measures approximately 7 inches in height by 6½ inches across its widest width. It features a handle and a removable lid that incorporates a hole for placement of a straw (not included). Across the knight’s chest are the words “Medieval Times” in raised letters.
The Mug, identified as the “Paris Balloon,” is pictured below:
The Mug, identified as the “Med Times Knights Head Gold,” is pictured below:
ISSUE:
Are the Drinking Vessels classified as hotel or restaurant ware of subheading 6912.00.20, HTSUS, or as other tableware of subheadings 6912.00.44 or 6912.00.48, HTSUS?
LAW AND ANALYSIS:
The matter is protested as a decision on classification. 19 U.S.C. § 1514(a)(2). Protestant’s AFR satisfies application criteria because Protestant alleges that CBP’s classification of the Drinking Vessels involves questions of law or fact which have not been ruled upon by the Commissioner of CBP or his designee or by the Customs courts. 19 C.F.R. § 174.24(b). Specifically, Protestant claims that relevant information concerning the physical characteristics and principal use of the Drinking Vessels demonstrates that the merchandise is not suitable for use in hotel or restaurants and was not considered by CBP when reaching its decision in New York Rulings Letter (“NY”) N131398, dated November 19, 2010. Thus, Protestant suggests that the merchandise is properly classified in subheading 6912.00.44, HTSUS, as Drinking Vessels and other steins.
Merchandise imported in the United States is classified under the HTSUS. Tariff classification is governed by the principles set forth in the General Rules of Interpretation (GRIs) and, in the absence of special language or context, which requires otherwise, by the Additional U.S. Rules of Interpretation. GRI 1 requires that classification be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes and, unless otherwise required, according to the remaining GRIs taken in their appropriate order. GRI 6 requires that the classification of goods in the subheadings of headings shall be determined according to the terms of those subheadings, any related subheading notes and, mutatis mutandis, to GRIs 1 through 5.
The following HTSUS provisions will be referenced:
6912.00 Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china:
Tableware and kitchenware:
Other:
6912.00.20 Hotel or restaurant ware and other ware not household ware.
Other:
Other:
6912.00.44 Drinking Vessels and other steins.
6912.00.48 Other.
* * *
Additional U.S. Rule of Interpretation 1(a), HTSUS, provides in relevant part, that:
In the absence of special language or context which otherwise requires:
…a tariff classification controlled by use (other than actual use) is to be determined in accordance with the use in the United States at, or immediately prior to, the date of importation, of goods of that class or kind to which the imported goods belong, and the controlling use is the principal use.
* * *
In understanding the language of the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity Description and Coding System may be utilized. The ENs, although not dispositive or legally binding, provide a commentary on the scope of each heading, and are generally indicative of the proper interpretation of the Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
There is no dispute that the merchandise is classifiable in heading 6912, HTSUS. As this dispute concerns the proper tariff classification of merchandise in the subheadings of heading 6912, HTSUS, GRI 6 applies.
In NY N131398, CBP classified the instant Drinking Vessels in subheading 6912.00.20, HTSUS, as hotel or restaurant ware and other ware not household ware, based on CBP’s prior ruling in Headquarters Ruling Letter (“HQ”) 082780, dated December 18, 1989. Upon review, however, we find that in NY N131398, CBP overly simplified the analysis set forth in HQ 082780, by stating that:
[I]n Headquarters Ruling 082780 Customs held that if a plate was emblazoned with a logo or crest of the hotel or restaurant, it was found to be hotel ware[,] regardless of the fact that without the logo, crest or symbol[,] the chinaware would be classified as household chinaware. In this case, both drinking vessels are emblazoned with the name of a hotel or restaurant and are therefore classifiable as hotel or restaurant ware.
Contrary to CBP’s statement in NY N131398, the presence (or absence) of a mark on tableware bearing the logo or crest of a hotel or restaurant is not the controlling factor when determining whether an article is properly described as hotel or restaurant ware of heading 6912, HTSUS. Rather, an article’s general physical characteristics, including any logo or crest markings, is merely one area of inquiry in a multi-factored analysis that CBP uses to determine the proper classification of the tableware.
In HQ 082780, for example, CBP classified a number of patterns of china dinnerware that were produced chiefly for household use, but were also marketed and sold to hotels and restaurants for use in their finer dining sections. After reviewing all of the evidence presented, CBP found that hotel china is often modified from household china in both physical and design characteristics because hotel china is heavier in weight and is stackable and chip resistant. Additionally, hotel china generally does not possess a center design. CBP also found that hotel china is typically less expensive than household china and is offered for sale by independent sales representatives to wholesalers or hotel chains, an industry that also has its own trade publications and trade shows. By contrast, household china was found to be generally lighter in weight, more expensive, and did not possess some of the characteristics of hotel ware. Furthermore, because the dinnerware at issue in HQ 082780 was also marked with the crest or initials of the establishment, this spoke in favor of it belonging to the class chiefly used in hotels or restaurants. Specifically, CBP commented that when household china has been modified so as to make it more suitable for restaurant and hotel use and to also include a hotel or restaurant logo, it is appropriately classified as hotel or restaurant ware:
[W]hen such modifications include the hotel or restaurant logo or name, it is obvious that such china is in a class chiefly for hotel purposes.
Thus, household china which has been special ordered and modified for hotel and restaurant use by incorporating the hotel/restaurant logo or name in the design, is no longer in the class of china for household use, but belongs to the class of china that is chiefly used for hotels and restaurants. (Emphasis added).
Consequently, in light of the multi-factor analysis described in HQ 082780, the mere presence or absence of a hotel or restaurant logo on an article of tableware is not controlling in determining the tariff classification of the merchandise.
Subheading 6912.00.20, HTSUS, is a “principal use” provision governed by Additional U.S. Rule of Interpretation 1(a), which the Federal Circuit has stated “calls for a determination as to the group of goods that are commercially fungible with the imported goods” so as to identify the “use which exceeds any other single use.” Aromont USA, Inc. v. United States, 671 F.3d 1310, 1312 (Fed. Cir. 2012) (quoting Primal Lite, Inc. v. United States, 182 F.3d 1362, 1365 (Fed. Cir. 1999); Lenox Collections v. United States, 20 Ct. Int’l Trade 194, 196 (1996). As such, the fact that the Drinking Vessels may have multiple significant uses does not proscribe the classification of the merchandise according to the principal use of the class or kind to which it belongs. Lenox Collections, 20 Ct. Int’l Trade at 196.
In order to determine the class or kind of good to which an article belongs, the Courts have instructed that CBP must examine all pertinent factors. Id. (citing United States v. Carborundum Co., 536 F.2d 373, 377 (Fed. Cir. 1976). These factors, commonly referred to as the “Carborundum Factors” are used to determine which goods are “commercially fungible with the imported goods.” Aromont, 671 F.3d at 1312 (quoting Primal Lite, 182 F.3d at 1365) (internal quotation marks omitted). These factors may include:
[U]se in the same manner as merchandise which defines the class; the general physical characteristics of the merchandise; the economic practicality of so using the import; the expectation of the ultimate purchasers; the channels of trade in which the merchandise moves; the environment of the sale, such as accompanying accessories and the manner in which the merchandise is advertised and displayed; and the recognition in the trade of this use. Id. (citing Carborundum, 536 F.2d at 377).
CBP has codified this principle in subsequent rulings. See, e.g., HQ W967570, supra; HQ H122957, dated October 9, 2012 (applying the Carborundum Factors to determine the principal use of tires for lawn and garden tractors). Consequently, CBP must determine whether pertinent factors indicate that the Drinking Vessels are of the class or kind of goods used principally as hotel or restaurant ware of subheading 6912.00.20, HTSUS, or whether they are classified as other tableware of subheadings 6912.00.44 or 6912.00.48, HTSUS.
CBP notes that the Court of International Trade (CIT) has previously addressed the principal use and commercial fungibility of ceramic steins that are decorated in detail with a brewer’s name or brewery identification and imported to be sold by breweries to customers and collectors. See G. Heilman Brewing Co. v. United States, 14 Ct. Int’l Trade 614 (1990). In G. Heilman Brewing, the Court applied the Carborundum Factors to determine whether the steins were of a class or kind of goods principally used as “Drinking Vessels and other steins,” under item 533.30 of the Tariff Schedule of the United States (TSUS) or as “art and ornamental articles,” under item A534.87, TSUS. There, however, the Court emphasized that because the steins were not well suited for serving beer, they were most appropriately classified as ornamental articles. Id.
Contrary to the facts presented in G. Heilman Brewing, there is no evidence in the instant the record to indicate that the Drinking Vessels are unsuitable for serving beverages. See supra. p. 4. Nonetheless, the CIT’s analysis in G. Heilman Brewing is useful for highlighting the dispositive factors used to determine the principal use of drinking vessels. Here, it is important note that the Court focused its analysis on the decorative qualities of the steins, their durability during frequent use and washing, their suitability for serving beverages, the expectations of the ultimate purchaser, as well as the intent of breweries to use the steins as advertisements to their customers. G. Heilman Brewing, 14 Ct. Int’l Trade at 620-21. As such, our analysis of the instant Drinking Vessels will involve many of the same factual inquiries at issue in G. Heilman Brewing.
Application of the Carborundum Factors in the instant case demonstrates that the Drinking Vessels are commercially fungible with other tableware that is not of a kind primarily used in hotels or restaurants.
The General Physical Characteristics of the Merchandise
The first Carborundum Factor, “the general physical characterisitics of the merchandise,” presents evidence that the Drinking Vessels are not commercially fungible with tableware of kind that is primarily used in hotels or restaurants. The terms “hotel and restaurant ware” are not defined in the Nomeclature or the ENs; however, CBP has issued several rulings in which it has described the common characteristics of such merchandise.
In HQ 082780, CBP stated that “hotel china is heavier in weight, is stackable, and chip resistant.” By contrast, CBP found that household china “is lighter in weight, is generally more expensive, and does not possess some of the characteristics of hotel ware.” Similarly, in HQ W967570, dated January 31, 2008, CBP considered whether porcelain tableware and kitchenware imported from France was principally for household use or hotel and restaurant use. There, CBP cited prior rulings and various reference books to determine what physical characteristics are indicative of household use versus restaurant and hotel use. In American china, such characteristics included composition, translucency, degree of absorption, and a very high mechanical shock resistance. Thickness was also a significant factor, as one cited source divided American hotel china, which it described as “vitrified ware of very high strength,” into three grades based on wall thickness: Grade (1), “Thick china,” which had 5/16 to 3/8 inch walls and is used in lunch counters and army messes; Grade (2), “Hotel China,” which contained 5/32 to ¼ inch walls and were used in hotels and restaurants; and Grade (3), “medium-weight China”, which had less than ¼ inch walls and was used in high-class eating places, home use, and also for numerous jars, trays, etc., in hospitals. See HQ W967570; HQ 959745, dated July 20, 1998; HQ 962208, dated April 19, 2000; Rexford Newcomb, Jr., Ceramic Whitewares, Pitman Publishing Corp., New York (1947) at pp. 222 and 227; Felix Singer & Sonja S. Singer, Industrial Ceramics, Chemical Publishing Co., Inc., New York (1963), at p. 1096. HQ W967570 also examined trade publications to determine the physical characteristics that are standard for restaurant and hotel ware, and quoted, “the single greatest thing a hotel demands and we produce are plain, white, round plates.” Consequently, it is CBP’s view that hotel and restaurant ware possess unique physical characteristics that render such articles heavier, stackable, and more resistant to chipping and breakage that other tableware.
In HQ 962208, dated April 19, 2000, CBP addressed the differences between chinaware marketed as household ware and that marketed as hotel ware, by comparing the descriptions of the china in the respective catalogs. The catalogs described the hotel ware as microwave and dishwasher proof, and addressed weight and stackability. The household ware was described as dishwasher proof, but was not advertised as microwave proof, and the weight and stackability was not addressed. Only the weight of one pattern was addressed. A 10 ½ inch plate sold as hotel/restaurant ware weighed approximately 1 pound and 9.5 oz. The same pattern plate sold as household ware weighed approximately 1 pound and 3 oz. Similarly, in G. Heilman Brewing, the CIT concluded that that testimony showing the ornamental beer steins to be susceptible to physical damage and unsuitable for frequent use or washing was persuasive in determining the proper tariff classification of the merchandise. G. Heilman Brewing, 14 Ct. Int’l Trade at 620. As such, evidence that an article of tableware is not stackable or is susceptible to chipping or breakage during repeated commercial use will weigh against a conclusion that such articles are properly described as hotel or restaurant ware.
The instant Drinking Vessels are irregularly shaped to resemble either a hot air balloon or a helmet of armor. They cannot be stacked, and the design of the Drinking Vessels is such that the articles are less chip resistant than typical drinking mugs. Moreover, although the Drinking Vessels feature a name or logo emblazoned on the outside of the article, the designs of the Drinking Vessels are unique to establishments in which they are sold, indicating that the merchandise is not suitable for sale to other hotels or restaurants and is therefore not commercially fungible with other hotel or restaurant ware. See Dependable Packaging Solutions, Inc. v. United States, No. 10-00330, slip op. 13-23 at 13 (Ct. Int’l Trade Feb. 20, 2013) (citing testimony that flower vase designs that are not new or unique to a particular company are evidence of commercial fungibility). As such, the general physical characteristics of the Drinking Vessels indicate that they are not designed to be principally used as hotel or restaurant ware.
The Expectation of the Ultimate Purchasers
The second Carborundum Factor, “the expectation of the ultimate purchasers,” also favors the conclusion that the Drinking Vessels are not primarily used for hotel or restaurant service. First, the record contains evidence that when the Drinking Vessels are sold in restaurants, the retail purchaser pays an added price for the pairing of a Mug with a beverage of his or her choosing and with the understanding that he or she may take the Mug home as a souvenir. Thus, the additional cost of a beverage sold in combination with a Mug indicates that consumers are willing to pay more for a beverage when they expect to keep the beverage container as a collectible souvenir or article for use at home. See Lenox Collections, 20 Ct. Int’l Trade at 197 (finding that a patron or purchaser’s willingness to pay an elevated price for a decorative spice container set was indicative of the consumer’s intent to primarily use the merchandise as a collectible set, as opposed to a utilitarian cooking container or accessory). Second, because the restaurant only presents the Drinking Vessels to those retail consumers who have ordered the higher-priced Mug and beverage combination, the expectations among ultimate purchasers are necessarily uniform that the Drinking Vessels are purchased as souvenirs to be taken home and away from the restaurant. See G. Heilman Brewing, 14 Ct. Int’l Trade at 620 (finding that purchasers’ intent to collect certain beer steins was relevant in determining whether the merchandise was classified as tableware or ornamental articles). Accordingly, we find that this information supports the conclusion that the Drinking Vessels are not principally used as hotel or restaurant ware.
The Channels of Trade in which the Merchandise Moves
The third Factor, “the channels of trade in which the merchandise moves,” supports a finding that the Drinking Vessels are not commercially fungible with hotel or restaurant ware. In HQ 082780, CBP found that hotel and restaurant ware is generally “offered for sale by independent sale representatives to wholesalers or hotel chains. By contrast, household ware is sold nationwide to department stores, gift stores, and directly to the consumer. See HQ 082780.
The record indicates that Progressive supplies the Drinking Vessels to hospitality and entertainment companies for subsequent sale to customers at hotels, restaurants, and related gift shops. Specifically, Progressive advertises the Drinking Vessels to the marketing departments of large resorts and restaurants, and the Drinking Vessels are not purchased by chefs or kitchen staffs in the normal course of food and food service supply orders. See G. Heilman Brewing, 14 Ct. Int’l Trade at 616, 621. Hotels and restaurants stock the Drinking Vessels on shelves in restaurants and gift shops, and the Drinking Vessels are sold directly to walk-in and dine-in customers. As such, we find that the channels in which this product is traded also indicate that the Drinking Vessels are not principally used as hotel or restaurant ware.
The Environment of Sale
Fourth, “the environment of sale” of the Drinking Vessels is also probative of whether the instant merchandise is commercially fungible with hotel and restaurant ware. Here, we note that in addition to sales of Mug and beverage combinations transacted inside restaurant dining areas, empty Drinking Vessels are also displayed and offered for sale in resort and restaurant gift shops. Additionally, there is no evidence in the record to indicate that the Drinking Vessels are sold in restaurant supply catalogues are stores.
Use in the Same Manner Which Defines the Class
Fifth, the actual use or, “use in the same manner which defines the class,” does not favor classification of the Drinking Vessels as tableware primarily used for hotel and restaurant purposes. Although the environment of sale of the merchandise includes the marketing of Drinking Vessels filled with a beverage in hotel and restaurant dining areas, the record indicates that commercial kitchens do not wash the Drinking Vessels for re-use and the serving of other customers. It is also undisputed that the irregular shape and embellished decoration of the Drinking Vessels render the articles unsuitable for stacking and susceptible to breakage, two qualities undesirable in hotel and restaurant ware that must withstand repeated use, washing, and frequent handling. Moreover, “where the physical characteristics factor so strongly favors one principal use, the actual use of an imported article will frequently not be controlling.” Dependable Packaging Solutions, Inc., No. 10-00330, slip op. 13-23 at 14 (internal quotation marks omitted) (citing Primal Lite, 182 F.3d at 1364 (1999) (“[A] classification covering vehicles principally used for automobile racing would cover a race car, even if the particular imported car was actually used solely in an advertising display.”)). Accordingly, this factor does not favor classification of the Drinking Vessels as hotel or restaurant ware of subheading 6912.00.20, HTSUS.
Economic Practicality of the Specified Use
The Drinking Vessels are not suited for repeated use in commercial dining rooms because they are not easily stacked and are susceptible to chipping and breakage. As such, if the Drinking Vessels were of a kind principally used as hotel or restaurant ware, economic practicality would require that the merchandise be modified so that is heavier in weight, more easily stored, and less prone to damage during frequent and repeated use. See HQ 082780. Consequently, the economic practicality
Recognition in the Trade of the Specified Use
Finally, the Carborundum Factor of “recognition in the trade of the specified use” is, in this instance, inconclusive. Evidence showing that the Drinking Vessels are not purchased by commercial kitchens and the fact that the Drinking Vessels are not re-used by hotel or restaurant dining rooms support a finding that the trade does not recognize the use of the instant merchandise as hotel or restaurant ware. However, we also note that the record does not contain sufficient facts to conclusively determine the recognition in the trade of the use of the Drinking Vessels. Accordingly, this factor is not very probative.
When considered in total, the Carborundum Factors–in particular the physical characteristics of the merchandise and the ultimate expectations of the patrons who purchase such articles–indicate that the Drinking Vessels are not principally used as hotel or restaurant ware. Consequently, the Drinking Vessels are not classifiable under subheading 6912.00.20, HTSUS.
Subheading 6912.00.44, HTSUS, provides for “Ceramic tableware, kitchenware, other household articles and toilet articles, other than or porcelain or china: Tableware and kitchenware: Other: Other: Other: Drinking Vessels and other steins.” The term “mug” is not defined in the Nomenclature or the ENs. However, in Ross Products, Inc. v. United States, 40 Cust. Ct. 158 (1958), the United States Customs Court determined that a decorated earthenware, barrel-shaped drinking vessel, about 3" high and 2" in diameter, with a curved handle, on top of which was a figure of a bird through which one could blow to make a whistle sound, used by children for the purpose of drinking milk, and not used with a saucer was a “mug” within the common understanding of that term. The tariff term “mug” was defined as a straight-sided or barrel-shaped vessel measuring about the same across the top as across the bottom. It is usually heavier than a cup, with a heavier handle, has a flat bottom and is not used with a saucer. Furthermore, the court noted that the company itself referred to the article as a “mug.” Id.
CBP considers articles meeting the court definition of “mug,” which are taller than they are wide, to be drinking vessels classifiable under subheading 6912.00.44, HTSUS. See HQ 957696, dated July 18, 1995 (classifying a 3” high, cylindrically-shaped vessel with a handle as a mug); HQ 067098, dated April 14, 1981 (classifying a 3" high and 3" in diameter vessel as a drinking mug); see also, NY 886462, dated June 15, 1993, and NY 890028, dated September 20, 1993.
The item identified in the instant case as the “Med Times Knights Head Gold” is a barrel-shaped ceramic vessel that features a handle and flat bottom. It is not used with a saucer, and the height of the vessel is approximately equal to its width. Here, we note that although the vessel is presented in the shape of an armored knight’s head, it possesses the general appearance and proportions of a mug. Insomuch as the “Med Times Knights Head Gold” vessel is described by the definition of the term “mug” in Ross Products, Inc., we find that the article is classifiable under subheading 6912.00.44, HTSUS.
By contrast, the item identified as the “Paris Balloon” is a spherically-shaped vessel that sits atop a solid, square-shaped base. The “Paris Balloon” does not possess a handle, and the diameter of the vessel at its lip is substantially larger than the width of its base. Additionally, when the lid of the vessel is removed for drinking purposes, the vessel resembles the shape of a goblet. As such, the “Paris Balloon” does not meet the definition of the term “mug,” but is instead provided for under subheading 6912.00.48, HTSUS.
HOLDING:
By application of GRI 1, the “Med Times Knights Head Gold” drinking vessel is classified in heading 6912, HTSUS. Specifically, by application of GRI 6, it is classifiable in subheading 6912.00.44, HTSUS, which provides for “Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china: Tableware and kitchenware: Other: Other: Other: Drinking Vessels and other steins.” The column one, general rate of duty is 10% ad valorem.
By application of GRI 1, the “Paris Balloon” drinking vessel is classified in heading 6912, HTSUS. Specifically, by application of GRI 6, it is classifiable in subheading 6912.00.48, which provides for “Ceramic tableware, kitchenware, other household articles and toilet articles, other than of porcelain or china: Tableware and kitchenware: Other: Other: Other: Other.” The column one, general rate of duty is 9.8% ad valorem.
Duty rates are provided for convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at http://www.ustic.gov.
In accordance with 19 U.S.C. 1625(c), this ruling will become effective 60 days after publication in the Customs Bulletin and Decisions.
EFFECT ON OTHER RULINGS:
In accordance with the above analysis, NY N131398, dated November 19, 2010, is hereby REVOKED.
This ruling will become effective 60 days after publication in the Customs Bulletin and Decisions.
Sincerely,
Myles B. Harmon, Director
Commercial and Trade Facilitation Division