CLA-2-46:RR:NC:SP:230 B84430
Ms. Judy Kearney
Network Brokers International, Inc.
Airport Industrial Office Park, Bldg. C-1D
145th Ave. & Hook Creek Blvd.
Valley Stream, N.Y. 11581
RE: The tariff classification of decorative "wraphia bows," made
of rayon strips, from China.
Dear Ms. Kearney:
In your letter dated April 16, 1997, on behalf of Berwick
Industries, Inc. (Berwick, PA), you requested a tariff
classification ruling.
A sample was submitted and will be retained for reference.
It is a retail display card holding six identical items described
as "wraphia bows." Each bow consists of several strips of rayon
which have been bundled together, tied into a bow formation and
knotted in the center. The individual strips, which have an
apparent width slightly over 5 mm, seem to have been
longitudinally creped, crinkled or similarly processed from much
wider (about 35 mm) strips, prior to bow formation.
The bows have an overall length of about 18 inches, and are
said to be intended for holiday decorating applications. They
are offered in three colors: "Imperial Red" (#T3600), "Oatmeal"
(#T3610) and "Burgundy" (#T3620).
The applicable subheading for the "wraphia bows" will be
4602.90.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for other (non-enumerated) articles made
directly to shape from plaiting materials. The rate of duty will
be 4.2%. Articles classifiable under this subheading are not
currently subject to quota or visa requirements.
You also asked about country of origin marking requirements,
given the following facts:
The rayon "wraphia" is made in Japan and put up on spools of 100
yards, and sent to China. In China, the manufacturer will cut the
ribbon to length, tie it into a bow formation and knot it in the center.
Six bows will then be put up on cards, packed into a larger carton
and exported to the USA.
We find that in this scenario the Japanese "wraphia" ribbon undergoes a substantial
transformation in China, meaning that the finished bows will be considered products of China.
Accordingly, the retail display cards are required to be marked with a phrase such as "Made
in China," legibly and in a conspicuous place. If a U.S. address also is shown on the card,
the country of origin marking must appear in close proximity to said address, in lettering of
comparable size.
This ruling is being issued under the provisions of Part 177 of the Customs
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with
the entry documents filed at the time this merchandise is imported. If you have any questions
regarding the ruling, contact National Import Specialist Paul Garretto at 212-466-5779.
Sincerely,
Gwenn Klein Kirschner
Chief, Special Products Branch
National Commodity
Specialist Division