CLA-2-49:S:N1:234 879419
Mr. Theodore E. Theodorsen
56 Old Ox Road
Manhasset, N.Y. 11030
RE: The tariff classification of handwritten solicitation
letters, with envelopes, from Jamaica.
Dear Mr. Theodorsen:
In your letter dated October 14, 1992, you requested a
tariff classification ruling.
You plan to send to Jamaica letterhead paper and letterhead
envelopes. You state that "these would be from various
organizations who contract us to write handwritten solicitation
letters on their behalf." After the letters are written and the
envelopes are addressed in Jamaica, they will be shipped back to
New York, where you will affix U.S. postage.
You suggest that this operation might fall under the "807
law," i.e., the tariff provision for articles assembled abroad
from fabricated U.S. components. In our judgment, however, such
tariff treatment for your proposed transaction would not be
appropriate.
The applicable subheading for the handwritten letters, with
their addressed envelopes, will be 4906.00.0000, Harmonized
Tariff Schedule of the United States (HTS), which provides for
handwritten texts. The rate of duty will be free. (It is
assumed that all of the letters will be individually handwritten;
this ruling will not apply to mechanical or photomechanical
reproductions.)
With regard to your question on the proper valuation, for
Customs purposes, of the imported product, we believe it would be
the sum of: a) the cost of the paper and envelopes, b) the cost
of transporting same to the Jamaican worksite, and c) the charge
for (or cost of) the work done in Jamaica. (This is advisory
only, and should not be construed as a "value ruling.")
The classification portion of 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 should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport