OT:RR:CTF:FTM H321716 MD
Center Director
Apparel, Footwear, and Textiles CEE
U.S. Customs and Border Protection
139 Southern Road
Savannah, Georgia 31405
RE: Application for Further Review of Protest No. 4503-21-101434; Tariff Classification of Sewing Thread; PTPA Eligibility; Women’s Garments
Dear Center Director:
The following is our decision regarding the Application for Further Review (“AFR”) of Protest No. 4503-21-101434, timely filed by Diaz Trade Law on September 15, 2021, on behalf of their client, Fair Indigo, LLC (“Fair Indigo” or “Protestant”), regarding the eligibility of four women’s garments for the preferential tariff treatment under the Peru Trade Promotion Agreement (“PTPA”). On November 2, 2021, counsel for Protestant filed a supplemental protest. This supplement detailed the provision of samples by Protestant to U.S. Customs and Border Protection (“CBP”) for testing. Specifically, Protestant provided samples of the sewing thread utilized to produce the subject merchandise. Protestant also provided independent laboratory analysis of the sewing thread at-issue within this supplement. The sewing thread was analyzed by the CBP Laboratory in Savannah, Georgia, and its report is included in this ruling. Ultimately, to determine the eligibility of the garments under the PTPA, an analysis into the tariff classification of the sewing thread used to make each garment was required.
FACTS:
The subject merchandise, entered into the United States on February 25, 2020, and June 24, 2020, respectively, is described as “Women’s Scoop Neck T-Shirt,” “Women’s Long Sleeve Scoop Neck T-Shirt,” “Women’s Square Neck Dress,” and “Women’s Maxi Skirt.” One entry was liquidated on March 19, 2021, with the “Women’s Scoop Neck T-Shirt” classified under subheading 6109.10.0040, Harmonized Tariff Schedule of the United States Annotated (“HTSUSA”), and the “Women’s Long Sleeve Scoop Neck T-Shirt” classified under 6109.10.0070, HTSUSA. The second entry was liquidated on July 2, 2021, with the “Women’s Square Maxi Dress” classified under subheading 6104.42.0010, HTSUSA, and the “Women’s Maxi Skirt” classified under subheading 6104.52.0010, HTSUSA.
According to documentation supplied by Protestant, the subject merchandise is described as follows. The Women’s Scoop Neck T-Shirt (“Style 02600”) is constructed from 95 percent organic Pima cotton and 5 percent spandex knit fabric. Style 02600 features short, hemmed sleeves, a scoop-front neckline, and a straight, hemmed bottom. The Women’s Long Sleeve Scoop Neck T-Shirt (“Style 02800”) is also constructed from 95 percent organic Pima cotton and 5 percent spandex knit fabric. Style 02800 features long, hemmed sleeves, a rib-knit, scoop-front neckline, and a straight, hemmed bottom. The Women’s Square Neck Dress (“Style 03806”) is constructed from 100 percent organic Pima cotton. Style 03806 features a squared front and back neckline and a hemmed bottom which reaches just below the mid-thigh. The Women’s Maxi Skirt (“Style 03810”) is constructed from 100 percent organic Pima cotton. Style 03810 features a hemmed-bottom and reaches just below the calf.
On January 19, 2021, CBP issued CBP Form 28 (Request for Information) to Protestant, specifically requesting the provision of entry packets, certificates of origin, purchase orders, fabric import records and invoices, cutting records, daily sewing records, export records, and affidavits from the producers of raw materials used in the production of the garments. On February 18, 2021, Protestant furnished CBP with the requested documents, except for information from their sewing thread supplier. According to the documents provided by Protestant, Protestant’s Peruvian manufacturer purchases yarn wholly formed in Peru from a domestic supplier, after which the manufacturer sends the yarn to a domestic fabric maker, alongside sewing thread, for conversion into fabric. In other words, the cotton knit fabric and the spandex knit fabric for the women’s apparel is knitted from yarns and fibers produced in Peru. The documentation further provides that once Protestant’s Peruvian manufacturer receives the converted fabric, they perform the cutting in-house, before either sewing the fabric in-house or via subcontracting with domestic workshops. When this fabric is sewn with spandex knit fabric, which the documents demonstrate is wholly formed in Peru, for Style 03806 and Style 03810, it is also done either in-house or via domestic subcontracting. Lastly, once the fabric has been sewn, Protestant’s Peruvian manufacturer performs finishing, quality inspection, packing, and shipping in-house.
CBP issued a final Notice of Action on March 2, 2021, pertaining to Style 03806 and Style 03810, determining that CBP had “verified the origin of the 100% cotton dresses and skirts” pursuant to the PTPA; however, “[t]he verification revealed that the good[s] do[] not qualify for preferential tariff treatment” because insufficient documentation was provided. On March 19, 2021, CBP issued a proposed Notice of Action, pertaining to Style 02600 and Style 02800, which asked Protestant to “provide [all] the documentation requested” in the January 19, 2021, CBP Form 28. Three days later, on March 22, 2021, Protestant supplied CBP with production information and affidavits from their Peruvian thread distributor, verifying the composition of the sewing thread and its Chinese origin. Protestant noted that it was still unable to contact their thread manufacturer in mainland China, ostensibly due to the ongoing Coronavirus (COVID-19) Pandemic, to receive the requested production information and affidavits. On June 24, 2021, CBP issued a final Notice of Action pertaining to Style 02600 and Style 02800. CBP stated that it had attempted to verify the originating status of the merchandise pursuant to the PTPA; however, “compliance with a rule of origin [could] not be[] substantiated.” Therefore, CBP concluded that “the goods do not originate” for the purposes of the PTPA.
Following the submission of Protest No. 4503-21-101434 on September 15, 2021, CBP issued a Preliminary Exam Finding on October 19, 2021, which stated that the requested sample quantity of sewing thread was neither provided by Protestant nor sufficient for CBP Laboratory Analysis to confirm its composition as made of 100% polyester fibers. Through counsel, Protestant filed a Supplementary Protest on November 2, 2021, asserting that they had submitted a spool of thread – measuring 5,000 yards – and requisite samples of each garment at-issue for review. Corresponding with the CBP Laboratory, it was established that they were in possession of each sample submitted by Protestant. On December 14, 2021, the CBP Laboratory concluded their analysis in Report No. SV20212623, detailing that each of the sewing threads in their possession was made of “2-ply yarns with a ‘Z’ twist [and] composed wholly of polyester staple fibers.”
ISSUES:
What is the tariff classification of the relevant sewing thread?
Is the subject merchandise eligible for preferential tariff treatment under the PTPA?
LAW AND ANALYSIS:
This matter is protestable under 19 U.S.C. §1514(a)(2) as a decision on classification, applicable rate, and amount of duties chargeable. 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)). Review of Protest No. 4503-21-101434 is properly accorded pursuant to 19 C.F.R. §174.24(b), as Protestant alleges that their protest involves a question of law or fact which has not been ruled upon by the CBP Commissioner or their designee, or by the Customs Courts; specifically addressing the question of whether or not merchandise at issue is eligible for preferential tariff treatment under the PTPA, when the subject goods were produced entirely in the territory of Peru, the United States, or both, and whether or not the tariff classification of the non-originating sewing thread used in the manufacture of the garments has affected the garments’ PTPA eligibility.
Tariff Classification
Classification of goods under the HTSUS is made in accordance with the General Rules of Interpretation (“GRI”). GRI 1 provides that the classification 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 GRI may be applied in order. Pursuant to GRI 6, classification at the subheading level uses the same rules, mutatis mutandis, as classification at the heading level.
The 2020 HTSUS provisions under consideration are as follows:
5508 Sewing thread of man-made staple fibers, whether or not put up for retail sale
* * *
6104 Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted
* * *
6109 T-shirts, singlets, tank tops and similar garments, knitted or crocheted
* * *
The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the “official interpretation of the Harmonized System” at the international level. See 54 Fed. Reg. 35127, 35128 (Aug. 23, 1989). While neither legally binding nor dispositive, the ENs “provide a commentary on the scope of each heading” of the HTSUS and are “generally indicative of [the] proper interpretation” of these headings. See id.
In applicable part, Note 5 to Section XI, HTSUS, reads:
For the purposes of heading 52.04, 54.01[,] and 55.08, the expression “sewing thread” means multiple (folded) or cabled yarn:
Put up on supports (for example, reels, tubes) of a weight (including support) not exceeding 1,000g;
Dressed for use as sewing thread; and
With a final “Z” twist.
Moreover, the General EN to Section XI, HTSUS, as applied to Chapter 55, HTSUS, reads as follows:
The Chapter covers the man-made fibres described in the General Explanatory Note to Chapter 54 when in the form of staple fibres (i.e., discontinuous fibres) or of certain filament tow; it also covers the products arising at the various stages of working these fibres or tow, up to and including yarn and woven fabrics.
The General EN to Section XI, HTSUS, as applied to Chapter 54, HTSUS, reads in relevant part:
The main synthetic fibres are:
[…]
(5) Polyester: Fibres composed of linear macromolecules having in the macromolecular composition at least 85% by weight of an ester of a diol and terephthalic acid.
* * *
Upon review, we find that the garments at-issue were correctly classified within various subheadings of either heading 6104, HTSUS, or heading 6109, HTSUS. Specifically, Style 02600 – a women’s t-shirt constructed from 95 percent organic Pima cotton and 5 percent spandex knit fabric is provided for within subheading 6104.42.0010, HTSUSA. Similarly, Style 02800 – a long-sleeved version of Style 02600 of identical construction – is properly classified within subheading 6109.10.0070, HTSUSA. Style 03806 – a women’s dress constructed from 100 percent organic Pima cotton – is likewise provided for within subheading 6104.42.0010, HTSUSA. Lastly, Style 03810 – a women’s skirt constructed from 100 percent organic Pima cotton – is classified within subheading 6104.52.0010, HTSUSA.
As supplied by Protestant, the sewing thread used in the production of the subject garments is of Chinese-origin and is purchased from a Peruvian, third-party distributor. Provided emails between Protestant and CBP demonstrate that Protestant’s local manufacturer either “[p]erform[s] the sewing of the fabric […] in-house” or sends the fabric “to a separate cooperative workshop for sewing. After the fabrics are sewn, Protestant’s local manufacturer performs “finishing, quality inspection, packing, and shipping” of the finished garments. These emails also indicate that the sewing thread is “imported from China” into Peru and is made of “100% polyester.” Moreover, an August 27, 2021, affidavit from Protestant’s distributor demonstrates that one spool of sewing thread, utilized by Protestant in their production of each of the garments at-issue, weighs a total of 139.80 grams. On this basis, Protestant asserts that the proper classification of the sewing thread is heading 5508, HTSUS, specifically subheading 5508.10.1000, HTSUSA, which provides for: “Sewing thread of man-made staple fibers, whether or not put up for retail sale: Of synthetic staple fibers.” We agree that the sewing thread at issue is classified in heading 5508, HTSUS.
Protestant supplied CBP with samples of its sewing thread and finished garments for laboratory analysis. Specifically, CBP sought to analyze the sewing thread provided by Protestant to confirm its composition as “100% polyester.” Within CBP Laboratory Report No. SV20212623, dated on December 14, 2021, the CBP Laboratory found:
The sample consists of a cone of yarn and three garments (a black skirt, a blue dress, and a purple top. The cone of yarn is black colored. The sewing threads from the black skirt are black colored. The sewing threads from the blue dress are blue colored. The sewing threads from the blue dress are blue colored. The sewing threads from the purple top are purple colored. The cone of yarn and all sewing threads are 2-ply yarns with a “Z” twist. Each is composed wholly of polyester staple fibers.
The findings of CBP Laboratory Report No. SV20212623 are consistent that of an independent laboratory report, commissioned by Protestant and supplied to CBP. This laboratory report, No. USA00043289, conducted by Intertek North America and reported on September 2, 2021, found that the provided sewing threads were made of “100% [p]olyester” following fiber analyses.
While not explicitly contemplated within the Intertek laboratory report, the findings of CBP Laboratory Report No. SV20212623 support the understanding that the subject merchandise is properly understood as “sewing thread” within the context of Note 5 to Section XI, HTSUS. Specifically, the CBP laboratory report details that the subject merchandise consists of multiple yarns up on supports - each of which does not exceed 1,000 grams in weight - is dressed for use as sewing thread and has a “Z” twist.
Moreover, the information contained within both CBP and Intertek laboratory reports provides sufficient information to determine the tariff classification of the sewing thread at the chapter and subheading level. As noted, polyester is contemplated within the General EN to Section XI as one of the “main synthetic fibres” within Chapter 54, HTSUS. As applied to Chapter 55, HTSUS, the General EN to Section XI provides that “man-made fibres described in the General Explanatory Note to Chapter 54” are classifiable within Chapter 55, HTSUS, “when in the form of staple fibres.” Here, CBP Laboratory Report No. SV20212623 is clear, the sewing thread is “composed wholly of polyester staple fibers.” Therefore, as a staple fiber made of a man-made material described in the General EN to Chapter 54, the sewing thread is properly classified within Chapter 55, HTSUS.
Specifically, the findings of CBP Laboratory Report No. SV20212623 and the documentation furnished by Protestant support their contention that the sewing thread utilized in the production of the subject garments is classifiable within subheading 5508.10.1000, HTSUSA. As noted within the August 27, 2021, affidavit from Protestant’s Peruvian supplier, one spool of the sewing thread utilized in the production of each of their garments at-issue weighs a total of 139.80 grams. CBP Laboratory Report No. SV20212623 elaborates that the sewing thread consists of “2-ply yarns with [a] “Z” twist.” As a multiple or cabled yarn, weighing no more than 1,000 grams, dressed for use as a sewing thread, and with a “Z” twist, the sewing thread satisfies the criteria for classification within subheading 5508, HTSUSA.
At the subheading level, CBP has consistently classified similar 100% polyester sewing thread within subheading 5508.10.1000, HTSUSA. In New York Ruling Letter (“NY”) M82060, dated April 11, 2006; CBP described the subject sewing thread as “100% polyester staple fiber multiple yarn with a final ‘Z’ twist.” When on a cardboard spool, the sewing thread “weigh[ed] 1.3 grams.” In NY A89399, dated November 29, 1996; CBP analyzed sewing thread described as “100 percent polyester […] 2-ply staple fiber yarn with a ‘Z’ twist.” Likewise, in NY A87644, dated September 19, 1996; CBP examined sewing thread which was described as “100 percent polyester […] 2-ply staple fiber yarn with a ‘Z’ twist.” The sewing thread “weigh[ed] approximately 14 grams.” Lastly, in NY 895614, dated March 15, 1994; CBP classified two sewing threads which were described as “two-ply polyester staple fiber yarns with a final twist in the ‘Z’ direction.” The total weight of the sewing thread, packaged on a plastic spindle, was “approximately 96 grams.” In each of the above rulings, the subject merchandise consisted of multiple yarns put up on supports, not exceeding 1,000 grams in weight, was dressed for use as sewing thread, and had a “Z” twist. As such, each sewing thread at-issue was classified within subheading 5508.10.1000, HTSUSA.
Here, the sewing thread at-issue also consists of multiple yarns up on supports, which does not exceed 1,000 grams in weight, is dressed for use as sewing thread, and has a “Z” twist. As a result, the sewing thread meets the requisite definitional criteria enumerated within Note 5 to Section XI, HTSUS. Specifically, the provided documentation establishes that the sewing thread is “composed wholly of polyester staple fibers […] 2-ply yarns with a ‘Z’ twist” and weighs a total of 139.80 grams when put up on a spool. Therefore, we find that the subject sewing thread is properly classified within subheading 5508.10.1000, HTSUSA, which provides for: “Sewing thread of man-made staple fibers, whether or not put up for retail sale: Of synthetic staple fibers.”
Eligibility for Preferential Tariff Treatment under the PTPA
The PTPA was signed by the Governments of the Republic of Peru and the United States of America on April 12, 2006. The PTPA was approved by the U.S. Congress with the enactment of the Peru TPA Implementation Act (“the Act”) on December 14, 2007, Pub. L. 110-138, 121 Stat. 1455 (19 U.S.C. § 3805). General Note (“GN”) 32 of the HTSUS implements the Peru TPA. GN 32(b) sets forth the criteria for determining whether a good is an originating good for the purposes of the PTPA. GN 32(b) states:
For the purposes of this note, subject to the provisions of subdivisions (c), (d), (m) and (n) thereof, a good imported into the customs territory of the United States is eligible for treatment as an originating good under the terms of this note if:
[T]he good is a good wholly obtained or produced entirely in the territory of Peru, the United States, or both;
[T]he good was produced entirely in the territory of Peru, the United States, or both; and
[E]ach of the non-originating materials used in the production of the good undergoes an applicable change in tariff classification specified in subdivision (n) of this note; or
[T]he good otherwise satisfies any applicable regional value content or other requirements specified in subdivision (n) of this note; and the good satisfies all other applicable requirements of this note; or
[T]he good was produced entirely in the territory of Peru, the United States, or both, exclusively from materials described in subdivision (b)(i) or (b)(ii) of this note.
Furthermore, GN 32(n), Chapter 61, Chapter Rule 2 provides, in pertinent part, that:
For purposes of determining whether a good of this chapter is originating, the rule applicable to that good shall only apply to the component that determines the tariff classification of the good and such component must satisfy the tariff change requirements set out in the rule for that good.
GN 32(n), Chapter 61, Chapter Rule 3 states:
Notwithstanding chapter rule 2 to this chapter, a good of this chapter containing fabrics of subheading 5806.20 or heading 6002 shall be considered originating only if such fabrics are both formed from yarn and finished in the territory of Peru, the United States, or both.
GN 32(n), Chapter 61, Chapter Rule 4 provides:
Notwithstanding chapter rule 2 to this chapter, a good of this chapter containing sewing thread of heading 5204 or 5401 shall be considered originating only if such sewing thread is both formed and finished in the territory of Peru, the United States, or both.
* * *
In this case, all components used in the production of the garments, other than the sewing thread, were wholly formed and finished in the territory of Peru. Merchandise of heading 6104, HTSUS, or heading 6109, HTSUS, qualifies for preferential tariff treatment under the PTPA if the requirements delineated within GN 32, HTSUS, are satisfied. As provided above, GN 32(b)(ii)(A) requires that the good are produced entirely in the territory of Peru, the United States or both. Additionally, GN 32(b)(ii)(A) also requires that any non-originating materials used in the production of the good undergoes an applicable change in tariff classification, specified in subdivision GN 32(n), HTSUS.
GN 32(n), Chapter 61, Chapter Rule 2 further specifies that, for the purposes of determining whether a good of Chapter 61 is originating, the rule applicable to that good shall only apply to the component that determines the tariff classification of the good, and that such component must satisfy the relevant tariff change requirements. The specific tariff shift requirements for goods classified in either heading 6104, HTSUS, or heading 6109, HTSUS, are also found within GN 32(n). Regarding any good of Chapter 61 containing fabrics of either subheading 5806.20 or heading 6002, HTSUS, GN 32(n) provides that these fabrics must be formed and finished in the territory of Peru, the United States, or both for the good to be considered originating. Pertaining to sewing thread contained within goods of Chapter 61, GN 32(n) also provides that, if such sewing thread is of either heading 5204, HTSUS, or heading 5401, HTSUS, that the thread must be formed and finished in the territory of Peru, the United States, or both for the good to be considered originating.
Applying the relevant criteria enumerated within GN 32, HTSUS, we find that Style 03806 and Style 03810 – Women’s garments solely constructed from organic Pima cotton fabric formed and finished in the territory of Peru – are classified within heading 6104, HTSUS, under GRI 1. As such, it is not necessary to employ an essential character analysis to classify the garments and GN 32(n), Chapter 61, Chapter Rule 2 is inapplicable. Documentation submitted by Protestant showed that the organic Pima cotton fabric, which is utilized to construct both Style 03806 and Style 03810 was produced entirely in the territory of Peru from Peruvian-origin yarns. Therefore, the organic Pima cotton is an originating material and is not required to undergo a GN 32(n) change in tariff classification. Moreover, both Style 03806 and Style 03810 are cut, sewn, and otherwise assembled within the territory of Peru. Since the sewing thread utilized in the manufacture of Style 03806 and Style 03810 is properly classified in heading 5508, HTSUS, as opposed to those enumerated within GN 32(n), Chapter 61, Chapter Rule 4, it does not need to be formed or finished in the territory of Peru, the United States, or both for the garments to be considered originating. As a result, we find that both Style 03806 and Style 03810 are eligible for preferential tariff treatment under the PTPA.
Similarly, Style 02600 and Style 02800 – Women’s shirts constructed from 95 percent organic Pima cotton and 5 percent spandex knit fabric – are properly classified within heading 6109, HTSUS, under GRI 1. As such, it is not necessary to employ an essential character analysis to classify the garments and GN 32(n), Chapter 61, Chapter Rule 2 is inapplicable. While both Style 02600 and Style 02800 are constructed from 95 percent organic Pima cotton and 5 percent spandex knit fabric, documentation supplied by Protestant detailed that this spandex knit fabric was produced entirely in the territory of Peru from yarn originating from the territory of Peru. Since the spandex knit fabric is a fabric classifiable within heading 6002, HTSUS, and is both formed from Peruvian-origin yarn and finished in Peru, the requirements of GN 32(n), Chapter 61, Chapter Rule 3 are satisfied. Likewise, Protestant’s supplied documentation also showed that the organic Pima cotton fabric which is utilized to construct both Style 02600 and Style 02800 was produced entirely in the territory of Peru. Therefore, the organic Pima cotton fabric is an originating material and is not required to undergo a GN 32(n) change in tariff classification. Moreover, both Style 02600 and Style 02800 are cut, sewn, and otherwise assembled within the territory of Peru. Since the sewing thread utilized in the manufacture of Style 02600 and Style 02800 is properly classified in heading 5508, HTSUS, as opposed to those enumerated within GN 32(n), Chapter 61, Chapter Rule 4, it does not need to be formed or finished in the territory of Peru, the United States, or both, for the garments to be originating. As a result, we find that both Style 02600 and Style 02800 are eligible for preferential tariff treatment under the PTPA.
HOLDING:
By application of GRI 1, the Women’s Scoop Neck T-Shirt (Style 02600) is classified under subheading 6109.10.0040, HTSUSA, which provides for “T-shirts, singlets, tank tops and similar garments, knitted or crocheted: Of cotton: Women’s or girls’: Other: T-shirts: Women’s.”
By application of GRI 1, the Women’s Long Sleeve Scoop Neck T-Shirt (Style 02800) is classified under subheading 6109.10.0070, HTSUSA, which provides for “T-shirts, singlets, tank tops and similar garments, knitted or crocheted: Of cotton: Women’s or girls’: Other: Other.”
By application of GRI 1, the Women’s Square Neck Dress (Style 03806) is classified under subheading 6104.42.0010, HTSUSA, which “Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: Dresses: Of cotton: Women’s.”
By application of GRI 1, the Women’s Maxi Skirt (Style 03810) is classified under subheading 6104.52.0010, HTSUSA, which provides for “Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: Skirts and divided skirts: Of cotton: Women’s.”
By application of GRI 1, the subject sewing thread is classified under subheading 5508.10.1000, HTSUSA, which provides for: “Sewing thread of man-made staple fibers, whether or not put up for retail sale: Of synthetic staple fibers.”
The women’s garments at-issue specifically, the Women’s Scoop Neck T-Shirt, Women’s Long Sleeve Scoop Neck T-Shirt, Women’s Square Neck Dress, and Women’s Maxi Skirt are eligible for preferential tariff treatment under the PTPA.
You are instructed to GRANT the protest.
You are instructed to notify the protestant of this decision no later than 60 days from the date of this decision. Any reliquidation of the entry or entries in accordance with the decision must be accomplished prior to this notification. Sixty days from the date of the decision, the Office of Trade, Regulations and Rulings will make the decision available to CBP personnel and the public on the Customs Rulings Online Search System (CROSS) at https://rulings.cbp.gov/, or other methods of public distribution.
Sincerely,
Yuliya A. Gulis
For Craig T. Clark, Director
Commercial and Trade Facilitation Division