The trade program eligibility of bows from Cambodia

N318958 April 30, 2021 CLA-2-46:OT:RR:NC:4:434 CATEGORY: Trade Agreement TARIFF NO.: 4602.90.0000 Terry Choi Silver Timing Ltd. Unit 801-802 8/F Pioneer Place 33 Hoi Yuan Road, Kwun Tong, Hong Kong CHINA RE: The trade program eligibility of bows from Cambodia Dear Mr. Choi: In your letter, dated April 19, 2021, you requested a ruling on eligibility under the Generalized System of Preferences (GSP) trade program for curly bows manufactured in Cambodia. Photos and descriptive information were submitted for review. Additional information was received in response to an inquiry from this office. Item SKU#26284, is a two-pack of gift bows on a retail backer card. The “curly bows” are fashioned from plastic ribbon; the ribbon measures approximately 6 mm in width. The ribbon has been curled and bundled to form a cascade effect and is stapled in the middle to hold its shape. The finished dimensions of the bows are approximately 6” in length by 4” in width. A small, adhesive-backed paperboard card is affixed to the underside for attaching to packages and the like. This office previously issued classification ruling number N318867, dated 4/15/21, which classified the bows in subheading 4602.90.0000, Harmonized Tariff Schedule of the United States (HTSUS). Under 19 U.S.C. 2463, as amended, a GSP eligible article may receive duty-free treatment if it is either wholly the growth, product, or manufacture of a designated beneficiary developing country (BDC) or a new or different article of commerce which has been grown, produced or manufactured in the BDC. The articles must also be imported directly into the customs territory of the U.S. from the BDC in order to qualify for duty-free treatment under GSP. As provided in General Note 3(c)(ii)(A), HTSUS, Cambodia is a BDC. In addition, the tariff provision under which the bows are classified, subheading 4602.90.0000, HTSUS, is a GSP eligible provision. In your submission, you state that, “all raw materials and process manufactured in Cambodia.” In a follow up email, you confirmed that the plastic sheeting from which the ribbons are made, and the ribbon itself, was made in Cambodia as well as the backer card, carton, and all manufacturing operations to turn the ribbon into the finished bows. Therefore, the bows meet the definition of goods that are “wholly the growth, product, or manufacture of a designated beneficiary developing country,” as per the requirements for GSP eligibility. Articles classifiable under subheading 4602.90.0000, HTSUS, which are products of Cambodia are currently entitled to duty free treatment under the GSP upon compliance with all applicable regulations. GSP, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term “GSP.” 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 Charlene Miller at charlene.s.miller@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division