OT:RR:CTF:FTM H313592 MJD
Center Director
U.S. Customs and Border Protection
Apparel, Footwear & Textiles CEE
555 Battery Street, Room 401
San Francisco, CA 94111
Attn: Daniel Wong, Import Specialist
Re: Application for Further Review of Protest No. 1512-20-100291; Classification of Men’s and Women’s graduated compression socks and graduated compression calf sleeves
Dear Center Director:
This is in reference to the Application for Further Review (“AFR”) of Protest No. 1512-20-100291 (“Protest”), timely filed by K&L Gates LLP, on February 6, 2020, on behalf of their client, mediUSA L.P. (hereinafter “Protestant” or “Medi”), contesting U.S Customs and Border Protection’s (“CBP”) tariff classification of several styles of men’s and women’s graduated compression socks and graduated compression calf sleeves under the Harmonized Tariff Schedule of the United States (“HTSUS”). Our decision is set forth below.
Protestant has asked that certain information submitted in connection with this Protest be treated as confidential. The request for confidentiality is approved. The information contained within brackets in Protestant’s submission and identified attachments to the Protest, forwarded to our office, will not be released to the public.
FACTS:
The merchandise at issue consists of several styles of Medi’s men’s and women’s graduated compression socks and graduated compression calf sleeves sold under the label CEP Compression (a division of Medi). The socks include knee high socks that cover the foot, ankle, and leg above the knee; and short socks that cover the foot and ankle. The calf sleeves cover the upper ankle and below the knee area. According to Protestant, the socks and calf sleeves are constructed of knit synthetic materials and are principally “marketed to athletes and other active lifestyle consumers as part of Medi’s CEP line of performance sportswear (http://www.cepcompression.com) for maximizing performance, energy, and endurance due to improved blood circulation and for the prevention of injuries.” Protestant further states that all of the socks and calf sleeves feature a minimum compression of 20 to 30 mm Hg, and are worn for the following reasons:
[T]o: (i) counter the effects of venous disease and improve venous valve and arterial functions by facilitating blood circulation; (ii) prevent blood pooling and various types of edema, or swelling; (iii) reduce the risk of Deep Vein Thrombosis; and (iv) stabilize muscles and joints to prevent certain types of injuries (e.g., shin splints, plantar fasciitis) and increase proprioception, which refers to an individual's sense of how the body is positioned in space.
The graduated compression socks and graduated compression calf sleeves were entered under subheading 6115.10.0500, HTSUSA (“Annotated”), which provides for “[p]anty hose, tights, stockings, socks and other hosiery, including graduated compression hosiery (for example, stockings for varicose veins) and footwear without applied soles, knitted or crocheted: Graduated compression hosiery (for example, stockings for varicose veins): Surgical panty hose and surgical stockings with graduated compression for orthopedic treatment.” The column one, general rate of duty is free. The socks were reclassified and liquidated under subheading 6115.10.4000, HTSUSA, which provides for “[p]anty hose, tights, stockings, socks and other hosiery, including graduated compression hosiery (for example, stockings for varicose veins) and footwear without applied soles, knitted or crocheted: Graduated compression hosiery (for example, stockings for varicose veins): Other graduated compression hosiery: Of synthetic fibers (632).” The column one, general rate of duty is 14.6% ad valorem. The calf sleeves were also liquidated and reclassified, but under subheading 6307.90.9889, HTSUSA, which provides for “[o]ther made up articles, including dress patterns: Other: Other: Other: Other: Other.” The column one, general rate of duty is 7% ad valorem.
ISSUE:
What is the tariff classification of the graduated compression socks and graduated compression calf sleeves?
LAW AND ANALYSIS:
Initially, we note that the matter is protestable under 19 U.S.C. § 1514(a)(2) as a decision on classification. The Protest was timely filed, within 180 days of liquidation of the entries. (Miscellaneous Trade and Technical Corrections Act of 2004, Pub.L. 108-429, § 2103(2) (B) (ii), (iii) (codified as amended at 19 U.S.C. § 1514(c) (3) (2006)).
Further Review of Protest No. 1512-20-100291 is properly accorded to Protestant pursuant to 19 C.F.R. § 174.24(c) because it involves matters previously ruled upon by the Commissioner of CBP or his designee or by the Customs courts, but facts are alleged, or legal arguments presented which were not considered at the time of the original ruling.
Classification under the HTSUS is determined in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may then be applied in order.
The 2018 and 2019 HTSUS headings under consideration are as follows:
6115: Panty hose, tights, stockings, socks and other hosiery, including graduated compression hosiery (for example, stockings for varicose veins) and footwear without applied soles, knitted or crocheted:
6115.10: Graduated compression hosiery (for example, stockings for varicose veins):
6115.10.0500: Surgical panty hose and surgical stockings with graduated compression for orthopedic treatment . . .
Other graduated compression hosiery:
6115.10.4000: Of synthetic fibers (632) . . .
* * * * *
6307: Other made up articles, including dress patterns:
6307.90: Other:
Other:
6307.90.98: Other . . .
Other:
6307.90.9889: Other . . .
* * * * *
The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the official interpretation of the Harmonized System at the international level. While not legally binding, the ENs provide a commentary on the scope of each heading of the HTSUS and are thus useful in ascertaining the proper classification of merchandise. It is CBP’s practice to follow, whenever possible, the terms of the ENs when interpreting the HTSUS. See T.D. 89-90, 54 Fed Reg. 35127, 35128 (August 23, 1989).
The EN to 61.15, provides, in relevant part, as follows:
This heading covers the following knitted or crocheted goods, without distinction between those for women or girls and those for men or boys:
[…]
(4) Graduated compression hosiery, e.g., stockings for varicose veins.
[…]
Subheading Explanatory Note.
Subheading 6115.10
For the purposes of subheading 6115.10, “graduated compression hosiery” means hosiery in which the compression is greatest at the ankle and reduces gradually along its length up the leg, so that blood flow is encouraged.
EN 63.07, provides, in pertinent part, that:
This heading covers made up articles of any textile material which are not included more specifically in other headings of Section XI or elsewhere in the Nomenclature.
* * * * *
Medi argues that the graduated compression socks and graduated compression calf sleeves are surgical panty hose and surgical stockings with graduated compression for orthopedic treatment classified in subheading 6115.10.0500, HTSUSA, which provides for “[p]anty hose, tights, stockings, socks and other hosiery, including graduated compression hosiery (for example, stockings for varicose veins) and footwear without applied soles, knitted or crocheted: Graduated compression hosiery (for example, stockings for varicose veins): Surgical panty hose and surgical stockings with graduated compression for orthopedic treatment.” As an initial matter, we note that the question presented concerns the classification of two articles whose physical characteristics substantially differ from one another. Whereas the compression sock consists of a closed-toe construction, the calf sleeve covers neither the ankle nor the foot. Because the compression socks and calf sleeves substantially differ from one another, the classification of each article must be separately addressed.
Inasmuch as the Medi compression socks are fully described by the terms of heading 6115, HTSUS, as graduated compression hosiery, there is no dispute that the compression socks are classified therein. Consequently, because this matter concerns the proper classification of the merchandise in the subheadings of heading 6115, HTSUS, GRI 6 applies. There is also no dispute at the 6-digit level that the compression socks are classified in subheading 6115.10, HTSUS, as “graduated compression hosiery.” Instead, the issue is at the 8-digit level and concerns whether the graduate compression socks are classified in subheading 6115.10.05, HTSUS, as “surgical panty hose and surgical stockings with graduated compression for orthopedic treatment,” or under subheading 6115.10.40, HTSUS, as “other graduated compression hosiery.”
Neither the HTSUS nor the ENs define “surgical panty hose and surgical stockings with graduated compression for orthopedic treatment.” When a tariff term is not defined by the HTSUS or the legislative history, its correct meaning is its common, or commercial, meaning. Rocknel Fastener, Inc. v. United States, 267 F.3d 1354, 1356 (Fed. Cir. 2001). “To ascertain the common meaning of a term, a court may consult ‘dictionaries, scientific authorities, and other reliable information sources’ and ‘lexicographic and other materials.” Id. (quoting C.J. Tower & Sons of Buffalo, Inc. v. United States, 673 F.2d 1268, 1271, 69 C.C.P.A. 128 (C.C.P.A. 1982); Simod Am. Corp. v. United States, 872 F.2d 1572, 1576 (Fed. Cir. 1989)).
CBP has consistently looked to the U.S. National Library of Medicine (“NLM”) at the National Institute of Health (“NIH”) for the commercial meaning of “surgical panty hose and surgical stockings with graduated compression for orthopedic treatment.” The NLM provides that medical-grade compression stockings are prescribed by a health care provider to treat someone who has just had surgery, or to treat someone with varicose veins or spider veins. Compression stockings work by gently squeezing the legs to move blood up the legs and improve blood flow throughout the legs. The stocking help with “[a]ching and heavy feeling in legs,” “[s]welling in legs,” “[p]reventing blood clots, primarily after surgery or injury when you are less active,” and “[p]reventing complications of blood clots in the legs, such as post-phlebitic syndrome (pain and swelling in the leg).”
Compression stockings provide the most pressure at the ankle and less as the stocking rises up the leg. This is also supported by the ENs to subheading 6115.10, HTSUS, which describe compression hosiery as “hosiery in which the compression is greatest at the ankle and reduces gradually along its length up the leg, so that blood flow is encouraged.” The NLM further states that one should get a prescription from a doctor to buy compression stockings and to “find a medical equipment store where they can measure your legs, so you get a good fit.” Moreover, the NLM explains that there are many different compression stockings, that come in various pressures, lengths, and colors, and one should consult their doctor to determine what stocking is right for them. National Institute of Health, U.S. National Library of Medicine, Compression Stockings, at https://medlineplus.gov/ency/patientinstructions/000597.htm (last visited, July 29, 2021).
Similarly, in Treasury Decision (T.D.) 76-133(3), 10 Cust B, 232 (1976), Customs offered the following description of surgical stockings:
For tariff classification purposes, a surgical stocking is a leg and foot covering which is made from a heavy gauge, opaque, elasticized fabric with either a one or two-way stretch, and which is worn, as a remedial support of the leg. It is designed for use in post-surgical support and in the treatment of thrombophlebitis, varicosities, edema, and other physical ailments, and is sold either singly or in pairs. It is not the type of merchandise commonly known as support hose which can be purchased in a variety of retail stores. Surgical stockings are usually obtained at the direction of a physician at certain medical supply outlets which have personnel specialty trained to measure and fit the merchandise to the legs of each individual patient.
CBP has previously considered the classification of graduated compression socks and whether or not they are surgical stockings. In Headquarters Ruling Letter (“HQ”) H237738, dated August 17, 2016, which revoked New York Ruling Letter (“NY”) N235286, dated December 7, 2012, CBP found that the “Surgeon’s Choice” and ”Boost” style of graduated compression hosiery was properly classified in subheading 6115.10.05, HTSUS, as surgical hosiery, stating the following:
Specifically, the “Surgeon’s Choice” and “Boost” hosieries are prescribed by physicians to prevent or treat venous disorders of the legs and feet, including blood clots (deep vein thrombosis), varicose veins, and lymphedema. The hosieries provide graduated compression in the range of 20-30 or 30-40 mm of mercury (mm HG), and are designed to help push blood out of the legs and feet by compressing surface veins to increase arterial pressure. Moreover, CBP observes that the “Surgeon’s Choice” and “Boost” hosieries are sold in medical and surgical supply stores, where trained personnel use detailed measurements of a patient’s leg to properly fit the stockings and socks.
Similarly, in HQ 963517, dated January 2, 2002, CBP found that Protestant’s graduated compression panty hose and stockings were properly classified as surgical panty hose and stockings with graduated compression for orthopedic treatment in subheadings 6115.12.1000, HTSUSA, and 6115.93.3000, HTSUSA. The graduated compression panty hose and stockings had a compression range of 20-30 mm Hg, were “packaged and sold by prescription as part of a line of hosiery with graduated compression which ranges from 20 to 50 mm Hg . . . [and] sold through medical supply houses and similar places by professionals skilled in fitting [the] stockings.” However, in the same case, CBP found that Protestant’s anti-embolism stockings were not surgical stockings and were classified in subheading 6115.93.3000, HTSUSA. Specifically, when comparing the anti-embolism stockings and the other graduated compression panty hose and stockings, CBP stated, “the anti-embolism stockings are distinguishable from the stockings discussed previously in that they are available without prescription and do not require specialized fitting.” Also, the anti-embolism stockings only had a compression of 18 mm Hg when CBP had previously established in that ruling that the minimum compression for surgical panty hose and stockings with graduated compression is 20-30 mm Hg.
Likewise, in HQ 959399, dated December 16, 1996, CBP rejected the classification of Protestants graduated compression panty hose and stockings as “surgical compression stockings” because the merchandise supplied less than 30 mm Hg of compression, was available for purchase without prescription, and was more “fashionable” than articles properly classified as surgical compression stockings. Also, in NY N057324, dated May 1, 2009, CBP classified athletic socks “marketed for use after intense training or competition for the purpose of revitalizing muscles in the lower legs” that are “compressed in the ankle at 15.71 mm Hg and in the calf at 21.89 mm Hg,” in subheading 6115.96.9020, HTSUSA. CBP stated that “[t]he items in question are for more general use, and are not prescribed by a physician or fitted as specifically as surgical graduated compression pantyhose or hosiery.” See also NY N240220, dated April 24, 2013; NY K80446, dated November 17, 2003; NY N004757, dated January 11, 2007; and NY 81986, dated February 24, 1997.
Based on the aforementioned, we find that the graduated compression socks in this case are not surgical panty hose and surgical stockings with graduated compression for orthopedic treatment classified in subheading 6115.10.05, HTSUS. First, medical-grade compression stockings are prescribed by a doctor, and the compression stockings at issue here do not require a physician’s prescription. Second, medical-grade compression stockings are sold in specialty stores where one’s leg must be measured and fitted by trained personnel. They are not the type of support hose which can be purchased in a variety of retail stores. The compression socks at issue here are sold online and in retail stores, and not do not require fitting by a trained professional.
Third, surgical panty hose and surgical stockings are designed for use post-surgery or after injury to prevent blood clots, swelling and aching, and to treat orthopedic ailments such as thrombophlebitis, varicosities, edema, spider veins, etc. As stated by Protestant, the CEP compression socks are “marketed to athletes and other active lifestyle consumers” and designed for “maximizing performance, energy, and endurance due to improved blood circulation and for the prevention of injuries.” This is further supported by the CEP website, under the page for Men’s compression socks, that states “CEP compression socks for men come in a number of different designs and various heights for running, skiing, basketball, tennis, and more. Increase traction, improve circulation, and give your muscles the support and stability they need to prevent injury and decrease recovery time.” The compression socks here are clearly designed for an active segment of the population and not for someone post-surgery or suffering from serious orthopedic ailments. Therefore, based on the aforementioned, the graduated compression socks in this case are not classified in subheading 6115.10.05, HTSUS, as surgical panty hose and surgical stockings with graduated compression for orthopedic treatment. Instead, we find that the graduated compression socks are simply graduated compression stockings for general use or active use and are properly classified under subheading 6115.10.40, HTSUS.
With regards to Medi’s graduated compression calf sleeves, we find that because the calf sleeves do not cover a wearer’s foot and ankle, the calf sleeves substantially differ from the Medi compression socks and must be classified separately. The doctrine ejusdem generis means literally, “of the same class or kind,” and as applied to questions of classification, it requires that imported merchandise possess the essential characteristics or purposes that unite articles enumerated eo nomine in order to be classified under the general terms of an HTSUS provision. Here, the footless calf sleeves cannot be described ejusdem generis by the terms “panty hose, tights, stockings, socks and other hosiery,” in heading 6115, HTSUS, because such articles are specifically designed to cover the foot of a wearer.
Having determined that Medi’s graduated compression calf sleeves are not described by the terms of heading 6115, HTSUS, we find that the instant calf sleeves are instead classified in heading 6307, HTSUS, as “other made up articles.” Heading 6307, HTSUS, covers made-up articles of any textile material that are not more specifically provided for in other headings of Section XI of the HTSUS. See EN 63.07. Since the calf sleeves are made up textile articles not more specifically provided for elsewhere in the tariff, we find that the calf sleeves are properly classified in heading 6307, HTSUS, and specifically in subheading 6307.90.9889, HTSUSA. We note that CBP has previously ruled on a variety of articles substantially similar to Medi’s compression calf sleeves, and in each case, has consistently classified such articles in heading 6307, HTSUS. See HQ H262218, dated February 6, 2020; HQ H281032, dated February 6, 2017; NY N248199, dated December 12, 2013; NY N206815, dated March 20, 2012; and HQ 950470, dated January 7, 1992.
Medi, however, disagrees and provides several arguments for why the graduated compression socks and graduated compression calf sleeves are classified in subheading 6115.10.05, HTSUS, as surgical panty hose and surgical stockings with graduated compression for orthopedic treatment. First, Protestant argues that subheading 6115.10.05, HTSUS, is a principle use provision which they interpret to mean that the socks and calf sleeves only need to meet a minimum compression of 20 to 30 mm Hg, an “industry standard agreed by CBP for conveying orthopedic benefits,” and be principally used for orthopedic purposes as it is defined in relation to heading 9021, HTSUS. Second, Protestant argues that CBP has incorrectly converted subheading 6115.10.05, HTSUS, into an actual use provision for requiring that surgical compression stockings be prescribed by a physician and measured and fitted by trained personnel. We disagree. We note that the criteria for surgical compression stockings are based on its commercial meaning provided for by the NLM and T.D. 76-133(3).
Furthermore, and as indicated above, CBP has previously examined classification of similar merchandise, and has found that compression strength and the use of physician prescriptions are important considerations in determining whether an article of graduated compression hosiery can be properly described as a “surgical stocking with graduated compression for orthopedic treatment” of subheading 6115.10.05, HTSUS. By contrast, CBP has consistently held that non-prescription graduated compression hosiery—identified by comparatively low compression strengths and suitable for purchase without specialty fitting—are not classifiable as “surgical” hosiery.
Second, Medi argues that all of the graduated compression socks and graduated compression calf sleeves have a minimum compression of greater than 20 mm Hg. Therefore, all of the products at issue in this Protest satisfy the minimum compression requirement for classification in subheading 6115.10.05, HTSUS. While we do not dispute the minimum compression of the socks and calf sleeves, which would support classification in subheading 6115.10, HTSUS, it is not the only criteria for classification of the graduated compression socks and compression calf sleeves as surgical stockings, and because the compression socks and calf sleeves do not meet the criteria provided for by the NLM and T.D. 76-133(3), they are not classified in subheading 6115.10.05, HTSUS.
Third, Medi argues that although their socks and calf sleeves are marketed towards an active segment of the population, they are, nevertheless, principally used for orthopedic purposes, insofar as those items are worn for the following reasons:
[T]o: (i) counter the effects of venous disease and improve venous valve and arterial functions by facilitating blood circulation; (ii) prevent blood pooling and various types of edema, or swelling; (iii) reduce the risk of Deep Vein Thrombosis; and (iv) stabilize muscles and joints to prevent certain types of injuries (e.g., shin splints, plantar fasciitis) and increase proprioception, which refers to an individual's sense of how the body is positioned in space.
Medi provides that while the HTSUS does not define the term “orthopedic,” it does define “orthopedic appliances” in Note 6 to Chapter 90, HTSUS, and this definition should be used to determine whether or not a product is used for orthopedic treatment. Note 6 to Chapter 90, HTSUS, provides the following:
For the purposes of heading 9021, the expression “orthopedic appliances” means appliances for:
Preventing or correcting bodily deformities; or
Supporting or holding parts of the body following an illness, operation or injury.
Orthopedic appliances include footwear and special insoles designed to correct orthopedic conditions, provided that they are either (1) made to measure or (2) mass-produced, entered singly and not in pairs and designed to fit either foot equally.
As a result, Protestant claims that with respect to Note 6 to Chapter 90, HTSUS, the compression socks and calf sleeves are used for orthopedic treatment as they “unquestionably are employed in the prevention and correction of bodily deformities” and because they are “routinely also used to treat the effects of certain types of illness (e.g., venous disease) and to support the leg following injury.” Thus, absent a definition of “orthopedic” in the HTSUS, Protestant argues that the term “orthopedic” cannot be limited to use in connection with illness or injury and seeks to expand the term to encompass the definition of “orthopedic appliances.” Compression socks and calf sleeves are not “orthopedic appliances.” Hence, the term “orthopedic appliances” defined in Note 6 to Chapter 90, HTSUS, is irrelevant to the classification of the particular products in this case.
Instead, since the term “orthopedic” is not defined in the HTSUS, CBP has relied upon the common and commercial meaning of the term defined in the NLM and T.D. 76-133(3). Again, both the NLM and T.D. 76-133(3) state that medical-grade compression stockings are prescribed by a doctor for the treatment of venous diseases or other serious medical conditions, and are sold in medical equipment stores where they can be measured to ensure a good fit. In contrast, Medi’s compression socks have none of the qualities defined in either the NLM or T.D 76-133(3). They do not require a prescription, they are not specially fitted by medical personnel, and are not advertised or sold for the treatment of venous diseases or other serious medical conditions. Medi’s socks are advertised for athletes to improve performance, energy, and endurance. While Medi claims in their Protest that their compression socks can also treat venous diseases, blood circulation, swelling, deep Vein Thrombosis, etc., these attributes cannot be compared to medical grade compression stockings that are used for serious orthopedic medical conditions and post-surgery to prevent blood clots and swelling. Actually, Protestant makes no claim that the compression socks in this case have any nexus to surgery or post-operative care.
Fourth, Medi provides that there is no longer a physician prescription requirement for ready-to-wear graduated compression garments, making the requirement outdated. Nevertheless, Medi provides evidence that physicians routinely recommend or “prescribe” the compression socks and calf sleeves to their patients. Again, we disagree with Protestant. We have no evidence that surgical panty hose and surgical stockings with graduated compression for orthopedic treatment no longer require a physician’s prescription nor did Protestant provide any evidence that a physician prescription is no longer required for these types of surgical compression hosiery. In fact, Sigvaris, another seller of compression socks, indicates on their website that “[c]ompression stockings with higher levels of compression are prescribed by doctors. The prescription will include the specific strength you need. By law, no prescription is required, but most pharmacies won’t dispense higher-level compression wear without a prescription.”
Lastly, Medi argues that the socks and calf sleeves require specialty training and fitting because they must be fitted based on the circumferential measurement of the wearers leg at the calf or ankle which ensures the proper compression. They provide that “the measurement and fitting process is integrated into the interaction with the retail customer and is a key component of the direction a prospective purchaser receives online. Furthermore, all CEP retailers are educated on this process and provided with tools needed to assist in this process.” We disagree with Protestant and find that what they say is specialty training and fitting is simply a sizing chart. The sizing chart shows the customer where to measure the ankle or calf so that the customer can choose the appropriate size on the chart.
Accordingly, we find that the graduated compression socks and graduated compression calf sleeves in this case are not surgical panty hose and surgical stockings with graduated compression for orthopedic treatment classified in subheading 6115.10.05, HTSUS. The graduated compression socks and calf sleeves are not prescribed by a physician, are not specially fitted by medical personnel, and are not advertised or sold for the treatment of venous diseases or other serious medical conditions. Instead, we find that the socks and calf sleeves are graduated compression hosiery designed for general use or active use and are properly classified in subheading 6115.10.40, HTSUS, and subheading 6307.90.98, HTSUS, respectively.
HOLDING:
By application of GRIs 1 and 6, Medi’s graduated compression socks are classified under heading 6115, HTSUS, specifically subheading 6115.10.4000, HTSUSA, which provides for “Panty hose, tights, stockings, socks and other hosiery, including graduated compression hosiery (for example, stockings for varicose veins) and footwear without applied soles, knitted or crocheted: Graduated compression hosiery (for example, stockings for varicose veins): Surgical panty hose and surgical stockings with graduated compression for orthopedic treatment.” The 2018 and 2019 column one, general rate of duty is 14.6% ad valorem.
The graduated compression calf sleeves are classified under heading 6307, HTSUS, specifically subheading 6307.90.9889, HTSUSA, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The 2018 and 2019 column one, general rate of duty is 7% ad valorem.
You are instructed to DENY the protest.
In accordance with Sections IV and VI of the CBP Protest/Petition Processing Handbook (HB 3500-08A, December 2007, pp. 24 and 26), you are to mail this decision, together with the CBP Form 19, to the Protestant no later than 60 days from the date of this letter. Any reliquidation of the entry or entries in accordance with the decision must be accomplished prior to mailing the decision.
Sixty days from the date of the decision, the Office of Trade, Regulations and Rulings will make the decision available to CBP personnel, and to the public on the Customs Rulings Online Search System (CROSS) at https://rulings.cbp.gov/ which can be found on the U.S. Customs and Border Protection website at http://www.cbp.gov and other methods of public distribution.
Sincerely,
For Craig T. Clark, Director
Commercial and Trade Facilitation Division