November 23, 2009
CLA-2 OT:RR:CTF:TCM H055387 CkG
Category: Classification
Tariff No.: 4203.21.60, 4203.21.80, 6116.93.94
Mr. Richard S. Luskin, Esq.
Black Diamond Equipment, Ltd.
2084 East 3900 South
Salt Lake City, UT 84124
Re: Reconsideration of NY N042400, NY N042401 and N042402;
classification of sports gloves
Dear Mr. Luskin,
This is in response to your letter of March 12, 2009, requesting reconsideration of New York Rulings Letters (NY) N042400, N042401, and N042402, dated November 14, 2008, with regard to the classification of nine styles of cold weather/winter sports gloves. We have since reviewed NY N042400, N042401, and N042402, and find them to be incorrect. For the reasons set out below, we are modifying these three rulings.
Pursuant to section 625(c)(1), Tariff Act of 1930 (19 U.S.C. §1625(c)(1)), as amended by section 623 of Title VI, notice proposing to modify NY N042400, NY N042401, and NY N042402 was published on July 17, 2009, in Volume 43, Number 28, of the Customs Bulletin. CBP received no comments in response to the notice.
FACTS:
The merchandise at issue is identified as Stormweight (Style # 801060), Windweight (Style #801062, 801063), Legend (Style # 801605, 801610), Fever (Style # 801564, 801566), Prodigy (Style # 801551, 801555), Guide (Style # 801511, 801512), Squad (Style # 801576, 801578), Renegade (Style # 801431, 801436), and Glissade (Style # 801724 and 801725).
Styles Legend, Fever, Prodigy, Guide, Squad and Renegade pertain to the FREERIDE line of gloves. The Black Diamond catalog states that “[t]he Freeride series features skiing specific designs intended to provide the most appropriate warmth and protection possible.”
Style Fever #801564 (men’s) and #801566 (women’s) is a lined and insulated glove made with a palmside, from fingertips to wrist, composed of over 90% goatskin leather. A goatskin leather palm overlay is also sewn across the palmside and overlaps four fingertips and the base of the backside knuckles. A strip of leather is sewn across the lower part of the backside. The backside thumb is made of a flocked polyurethane (PU) fabric which serves as a nose wipe. The remainder of the outer shell includes a small portion of the bottom of the palmside at the wrist, the backside which contains a zippered pocket into which a heat pack is inserted for extra warmth, fourchettes, sidewalls, extended gauntlet cuff and is made up of a woven fabric that has been laminated to a knit pile fabric on the underside. The gloves also feature an elasticized wrist, a hook and clasp, an inner waterproof barrier, and a ribbed knit cuff extending beyond the gauntlet bottom.
Style Legend #801605 (men’s) and #801610 (women’s) is a lined and insulated glove made with a palm side, from fingertips to wrist, composed of goatskin leather. Goatskin leather also makes up the majority of the backside and sidewalls. The remainder of the glove, which includes a portion of the fourchettes, the bottom portion of the backside, and the cuff, are made of a coated woven fabric. The backside thumb is made of a flocked PU fabric which serves as a nose wipe. Other features include a hook and loop fastener at the cuff, a hook and clasp, and irregular shaped molded foam padding placed over two of the backside fingers and across the backside knuckles.
Style Prodigy #801551 (men’s) and #801555 (women’s) is a lined and insulated glove. The gloves feature a palm side, from fingertips to wrist, and a complete index finger, made up of over 90% goatskin leather, which extends across the backside knuckles and makes up the sidewalls of the thumb and index finger. A goatskin leather palm overlay is sewn across the palmside. Leather inserts make up three of the backside fingertips, the backside finger knuckles, and the base of the backside thumb. The remainder of the outer shell, which includes a small portion of the palm side at the wrist, fourchettes, backside and extended gauntlet, are made up of a coated woven textile fabric. The outer gloves also feature an elasticized wrist, a drawstring tightener sewn into the gauntlet hem, and a backside thumb made up of a flocked PU fabric which serves as a nose wipe. The glove has a dedicated glove liner made of a coated woven fabric. The dedicated liners are lined and insulated and are attached to the outer gloves by means of hook and loop fabric. The dedicated glove liners feature fourchettes and a pull tab sewn to the outer edge of the cuff that enables the liners to be pulled out more easily.
Style Guide #801511 (men’s) and #801512 (women’s) is a lined and insulated glove. The gloves are made of a palm side, from fingertips to wrist, made up of over 90% goatskin leather, which also extends to form the sidewalls and overlaps four fingertips. A goatskin leather palm patch is sewn across the palmside. The backside thumb is made of a flocked PU fabric which serves as a nose wipe. The remainder of the glove, which includes a small portion of the bottom of the palmside at the wrist, the backside, fourchettes, and extended gauntlet cuff, are made up of a coated woven fabric. A leather goatskin overlay is sewn across the backside knuckles, a portion of which also features an irregular shaped molded foam padding. Additional features include an elasticized wrist and a drawstring tightener sewn into the gauntlet hem. The glove has a dedicated glove liner made of a coated woven fabric. The dedicated liners are lined and insulated and are attached to the outer glove by means of hook and loop fabric. The dedicated glove liners feature fourchettes, a knit berber lining, and a pull tab sewn to the outer edge of the cuff that enables the liners to be pulled out more easily.
Style Squad #801576 (men’s) and #801578 (women’s) is a lined and insulated glove made of a palm side, from fingertips to wrist, composed of over 90% goatskin leather. Goatskin leather also makes up the fourchettes, sidewalls, and overlaps the fingertips of the index finger, middle finger and thumb. Vented goatskin leather makes up a portion of the backside at the knuckles, the backside of the index finger, middle finger, and a portion of the ring finger. Beneath the vented goatskin leather is an inner liner made of a coated woven fabric. The remainder of the outer shell, which includes a small portion of the bottom of the palmside at the wrist, the backside of the pinky finger and a portion of the backside ring finger, and extended gauntlet cuff, is made up of a woven fabric with a coating on the underside. Additional features include a partially elasticized wrist, a hook and clasp, a backside thumb made of a flocked PU fabric which serves as a nose wipe, and a second inner cuff with a drawstring tightener sewn into the hemmed bottom measuring approximately 1½ inches sewn to the inner edge of the extended gauntlet cuff.
Style Renegade #801431 (men’s) and #801436 (women’s) is a lined and insulated glove made up of a palmside, from fingertips to wrist, composed of over 90% goatskin leather. Goatskin leather also makes up the sidewall of the index finger. The balance of the outershell, including a small portion of the bottom of the palmside at the wrist, the fourchettes, backside and cuff, are made up of a woven fabric that has been laminated to a knit pile fabric on the underside. Additional features include an elasticized wrist, a hook and clasp, an inner waterproof barrier, a hook and loop fastener on the cuff, a heavyweight berber fleece lining, and a backside thumb made of a flocked PU fabric which serves as a nose wipe.
Style Glissade pertains to the ASCENT line of gloves, which are described in the black diamond catalog as “designed for general mountaineering, alpine climbing, or use in winter environments where breathability and temperature regulation are crucial.” Style Glissade #801724 (men’s) and #801725 (women’s) is a lined and insulated glove with a complete palmside, from fingertips to wrist, composed of over 90% goatskin leather with Kevlar stitching. Goatskin leather also makes up the sidewall of the index finger and thumb. The balance of the outershell, which includes a small portion of the bottom of the palmside at the wrist, the fourchettes, backside and extended gauntlet cuff, is made up of a woven fabric that has been laminated to a knit pile fabric on the underside. Additional features include a partially elasticized wrist, a hook and clasp, an inner waterproof barrier, a backside thumb made of a flocked PU fabric which serves as a nose wipe, and a second inner cuff which features a drawstring tightener sewn into the hemmed bottom that measures approximately 1½ inches sewn to the inner edge of the extended gauntlet cuff.
Styles Windweight #801062 (men’s) and #801063 (women’s) and Stormweight (#801060) pertain to Black Diamond’s LINER series. The Black Diamond catalog describes them as “comfortable, fitted gloves that can be used on their own or with the ASCENT series.”
Style Stormweight #801060, is described as a pair of unisex gloves/liners. The gloves are made up of 100% polyester knit fabric that features a breathable windstopper membrane on the inner surface which is sandwiched between a finely knit polyester fabric on the inner surface and a brushed polyester fabric on the outer surface of the glove. A goatskin leather overlay makes up the palmside, from fingertips to wrist, and overlaps the fingertips and thumb tip. Other features include a partially elasticized wrist, a hook and clasp, and fourchettes.
Style Windweight #801062 (men’s) and #801063 (women’s) is a cold weather glove/liner made up of a 100% knit polyester fleece outer shell. A goatskin suede leather palm patch is located across the center of the palm and covers a portion of the base of the index finger and thumb. The tip of the palmside thumb, index and middle fingers feature a small silicon dotted overlay. Other features include a partially elasticized wrist, knit polyester fleece fourchettes and sidewalls, and a hook and clasp.
Styles #801551, #801555, #801511 and #801512 were classified in subheading 4203.21.8060, HTSUS, which provides for “articles of apparel and clothing accessories, of leather or of composition leather: gloves, mittens and mitts: specially designed for use in sports: other…other.”
Styles #801564, #801724, #801605, #801576, #801431 were classified in subheading 4203.29.3020, HTSUS, which provides for “articles of apparel and clothing accessories, of leather or of composition leather: gloves, mittens and mitts: other: other: other: men’s…lined.”
Styles #801566, #801610, #801578, #801436 and #801725 were classified in subheading 4203.29.5000, HTSUS, which provides for “articles of apparel and clothing accessories, of leather or of composition leather: gloves, mittens and mitts: other: other: other: for other persons: lined.”
Style #801060 was classified in subheading 4203.29.40, HTSUS, as “articles of apparel and clothing accessories, of leather or of composition leather: gloves, mittens and mitts: other: other: for other persons: not lined”
Styles #801062 and #801063 were classified in subheading 6116.93.94, HTSUS, which provides for “gloves, mittens and mitts, knitted or crocheted: other: of synthetic fibers: other: other: with fourchettes.”
ISSUE:
Whether the material of the palmside or outer shell imparts the essential character of the subject gloves.
Whether the subject gloves are classified as gloves specially designed for use in sports or “other” gloves
LAW AND ANALYSIS:
Classification of goods under the HTSUS is governed by the General Rules of Interpretation (GRI). GRI 1 provides that 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 GRIs 2 through 6 may then be applied in order.
The HTSUS provisions at issue are as follows:
4203: Articles of apparel and clothing accessories, of leather or of composition leather:
Gloves, mittens and mitts:
4203.21: Specially designed for use in sports:
Ski or snowmobile gloves, mittens and mitts:
4203.21.55: Cross-country ski gloves, mittens and mitts
4203.21.60: Other
4203.21.80: Other
4203.29: Other:
Other:
4203.29.30: Men's
4203.29.3020: Lined
For other persons:
4203.29.40: Not lined
4203.29.50: Lined
* * * * *
6116: Gloves, mittens and mitts, knitted or crocheted
Other:
6116.93: Of synthetic fibers:
6116.93.08: Other gloves, mittens and mitts, all the foregoing specially designed for use in sports, including ski and snowmobile gloves, mittens and mitts……
Other:
Other:
6116.93.94: With fourchettes
* * * * *
6216: Gloves, mittens and mitts:
Other:
Of man made fibers:
6216.00.46: Other gloves, mittens and mitts, all the foregoing
specially designed for use in sports, including ski and
snowmobile gloves, mittens and mitts……
* * * * *
Since the gloves at issue are composite goods of leather and textile, classification is determined by application of GRI 3(b). GRI 3(b) provides that composite goods consisting of different materials or made up of different components, shall be classified as if they consisted of the material or component which gives them their essential character. Court decisions on the essential character for 3(b) purposes have looked primarily to the role of the constituent material in relation to the use of the goods. See Better Home Plastics Corp. v. U.S., 915 F. Supp. 1265 (CIT 1996), aff’d 119 F. 3d 969 (Fed. Cir. 1997); Mita Copystar America, Inc. v. U.S., 966 F.Supp. 1245 (CIT 1997), rehear’g denied, 994 F. Supp. 393 (1998).
You contend that, except for Style #801725, the essential character of the merchandise is imparted by the textile component. As such, you argue that the merchandise is classified in heading 6216, HTSUS. You argue that Style # 801725 is classified in heading 4203, HTSUS. Alternatively, you contend that Style #’s 801060, 801605, 801610, 801564, 801566, 801578, 801576, 801431 and 801436 are classifiable in heading 4203, HTSUS and Style # 801062 is classified in heading 6116, HTSUS.
While you contend that the outer shell imparts the essential character to Style #s 801605, 801610, 801564, 801566, 801555, 801551, 801511, 801512, 801576, 801578, 801431 and 801436 because it provides waterproofing and breathability, the Black Diamond catalog indicates that the Gore-Tex inserts are also waterproof and breathable. Furthermore, the coating on the outer shell limits the breathability of the woven nylon material, decreasing the role of the outer shell in relation to the glove as a whole. Therefore, the essential character of the gloves is imparted by the leather palmside, which provides the grip, and reinforces the area of stress caused by grasping the ski poles. See HQ 089576, dated August 27, 1991.
We agree that the essential character of Style #s 801724 and 801725 is imparted by the leather palmside, which imparts the grip and is thus crucial for climbing.
The suede portion of Style #s 801062 and 801063 plays a minimal role in relation to the textile portion, in that it covers a small area of the glove and is not otherwise prominent. The essential character is thus imparted by the wind-resistant knit Polartec shell. Insofar as the gloves are classified by the knit shell, classification in heading 6216, HTSUS, is inapplicable insofar as the legal text of heading 6216 is limited to gloves, mittens and mitts not knitted or crocheted. As such, style #s 801062 and 801063 are classified in heading 6116, HTSUS.
At the six-digit subheading level, you request classification of the subject articles as gloves specially designed for use in sport, principally skiing. For articles governed by principal use, Additional U.S. Rule of Interpretation 1(a), HTSUS, provides that, in the absence of special language or context which otherwise requires, such use "is to be determined in accordance with the use in the United States at, or immediately prior to, the date of importation, of goods of that class or kind to which the imported goods belong, and the controlling use is the principal use." In other words, the article's principal use at the time of importation determines whether it is classifiable within a particular class or kind.
While Additional U.S. Rule of Interpretation 1(a), HTSUS, provides general criteria for discerning the principal use of an article, it does not provide specific criteria for individual tariff provisions. However, the CIT has provided factors which are indicative but not conclusive, to apply when determining whether merchandise falls within a particular class or kind. They include: general physical characteristics, the
expectation of the ultimate purchaser, channels of trade, environment of sale (accompanying accessories, manner of advertisement and display), use in the same manner as merchandise which defines the class, economic practicality of so using the import, and recognition in the trade of this use. See United States v. Carborundum Company, 63 CCPA 98, C.A.D. 1172, 536 F. 2d 373 (1976), cert. denied, 429 U.S. 979 (hereinafter Carborundum).
In Sports Industries, Inc. v. United States, 65 Cust. Ct. 470, C.D. 4125 (1970), the court, in interpreting the term "designed for use," examined not only the features of the articles, but also the materials selected and the marketing, advertising and sale of the article. A conclusion that a certain glove is "specially designed" for a particular sport requires more than a mere determination of whether the glove or pair of gloves could possibly be used while engaged in that sport. See HQ 965714, dated November 15, 2002; HQ 965157, dated May 14, 2002. To determine whether an article is specially designed for a specific sport requires consideration of whether the article has particular features that adapt it for the stated purpose.
With regard to the proper classification of ski gloves, the court in Stonewall Trading Company v. United States, Cust. Ct. 482, C.D. 4023 (1970) held that ski gloves possessing the following features were specially designed for use in the sport of skiing:
A hook and clasp to hold the gloves together;
An extra piece of vinyl stitched along the thumb to meet the stress
caused by the flexing of the knuckles when the skier grasps the ski
pole;
3) An extra piece of vinyl with padding reinforcement and inside stitching
which is securely stitched across the middle of the glove where the
knuckles bend and cause stress;
4) Cuffs with an elastic gauntlet to hold the gloves firm around the wrist so as
to be waterproof and to keep it securely on the hand.
The Stonewall criteria are used as a guideline to aid in the classification of sports gloves and mittens, but they are neither mandatory nor all-inclusive in determining whether a glove merits classification under this provision. A case by case analysis will be used by CBP in determining whether a glove's design merits classification as a ski glove under headings 6116 or 6216, HTSUS. See Headquarters Ruling Letter (HQ) 954733, dated December 21, 1993; HQ 089589, dated August 19, 1991. Even if the Stonewall criteria are met, a glove is not classifiable as a ski glove if it is not functionally
Jul 8, 1993. In addition to the Stonewall criteria outlined above, CBP consistently considers the protective features of a glove (e.g., resistance to wind and water) and how
the gloves are advertised and sold. See e.g., HQ 956188, dated December 29, 1994; HQ 954425, dated September 10, 1993; HQ 953629, dated Jul 8, 1993; and HQ 088374, dated June 24, 1991.
Examination of the FREERIDE line of gloves (Style #’s 801605, 801610, 801564, 801566, 801551, 801555, 801511, 801512, 801576, 801570, 801431 and 801436) yields the finding that they meet several of the Stonewall criteria. All styles in the FREERIDE line possess an elastic gauntlet to hold the gloves firm around the wrist, and thus satisfy the fourth Stonewall criterion. However, some styles lack some of the remaining Stonewall criteria. The Prodigy, Squad and Renegade gloves all lack reinforcement of the knuckles. The Guide and Prodigy gloves also lack a hook and clasp to keep the gloves together. Only the Fever and Renegade gloves feature extra stitching along the thumb.
However, as noted above, the Stonewall criteria are not necessarily determinative of the classification of a glove. CBP will also examine additional physical characteristics such as the construction of the glove, the materials used and their resistance to the elements as well as the marketing, advertisement and sale of the subject gloves.
The general physical characteristics of the FREERIDE gloves evidence a design specific to skiing. This is demonstrated by the gloves' incorporation of such components as Gore-Tex and Primaloft insulation, the elasticized wrists with a drawstring tightener and extended gauntlet cuff which effectively keep moisture out, the use of leather palm reinforcement which enables a more secure grip than does plastic, the nose wipe on the backside thumb and the overall sturdy appearance and sound workmanship. Furthermore, the environment of sale of the gloves indicates that they are specially designed for use in skiing. The importer’s catalog describes the FREERIDE line of gloves as featuring “skiing-specific designs.” The Prodigy, Legend, Guide, and Renegade gloves are featured on outdoor sporting goods websites such as Altrec, www.Backcountry.com and www.MountainGear.com as ski gloves. The FREERIDE gloves are thus designed to withstand the rigorous, cold and wet conditions of extreme skiing, are marketed as ski gloves, and are sold in the same channels of trade as other ski gloves. Insofar as no evidence has been presented to support a finding that the gloves are designed, marketed or sold as cross-country gloves of subheading 4203.21.55, HTSUS, they are classified as “other” ski gloves of subheading 4203.21.60, HTSUS.
Style Glissade (Style #s 801724 and 801725) is described in the black diamond catalog as “designed for general mountaineering, alpine climbing, or use in winter environments where breathability and temperature regulation are crucial.” Like the ski gloves in the Freeride series, the Glissade gloves feature an elasticized wrist, a hook
and clasp, an extended gauntlet cuff with drawstring tightener, and reinforced stitching along the thumb portion. Due to the lack of sufficient evidence demonstrating that the Glissade glove is designed, marketed or sold as a ski glove, it is classified in subheading 4203.21.80, HTSUS, as other gloves specially designed for use in sports.
Similarly, the Black Diamond catalog does not indicate that Windweight style #s 801062 (men’s) and #801063 (women’s) and Stormweight (Style # 801060) have a specialized design for use in skiing. Both gloves are constructed primarily of knit polyester fleece. CBP has previously deemed gloves of knit fabric to be unsuitable for use in skiing due to the tendency of the fabric to retain and absorb moisture and dry slowly, as well as the tendency of snow to adhere to such fabric. See HQ 953629, dated Jul 8, 1993, in which two styles of gloves with an additional plastic insert or an inner waterproof barrier did not render the glove sufficiently water resistant due to the tendency of snow to adhere to the acrylic material of the glove. HQ 954425, dated September 10, 1993, similarly noted that “Gloves that are comprised of significant amounts of knit fabric which allow moisture to penetrate the wearer’s hands are not suitable for use in skiing.”
Furthermore, the partially elasticized wrists of both liner styles do not provide a sufficiently tight seal against snow and water, particularly given the absence of a drawstring tightener or additional knit cuff. See HQ 952393, dated December 30, 1992. The suede palm patch of the Windweight liner also does not provide sufficient resistance to snow and damp conditions. CBP observed in HQ 088374, dated June 24, 1991, that suede leather was not particularly well suited for a ski glove: “Both glove styles are largely covered in sueded leather… suede will absorb and retain moisture, stretch out of shape and/or expand, and dry slowly, which makes it highly unsuitable to the sport of skiing where contact with snow is a characteristic occurrence; treatment of the skins with a water-repellent chemical may protect such gloves from minor contact with the elements but does not transform these gloves into gloves specially designed for use in skiing.” The use of suede to reinforce the palm in order to provide better grip and texture, on the other hand, has been held to constitute a useful feature of ski gloves where the glove had other, sufficient water-resistant properties. See HQ 954733, dated December 21, 1991, in which gloves with a suede leather palm and additional inner linings of Gore-Tex, foam, and thinsulate were classified as ski gloves. Moreover, the suede palm patch does not extend past the base of the thumb and index finger. The Windweight gloves only feature a silicone overlay on the tip of the palmside thumb, index and middle fingers. The polyester fleece on the remainder of the palmside and the rest of the glove remains uncovered. The leather overlay on the palmside of the Stormweight gloves, on the other hand, provides for greater water protection and a surer grip, extending from the fingertips to the wrist. Finally, the liner gloves are made from a lightweight, sheer construction and lack padding to protect hands from injuries resulting from falls.
The tag on the Stormweight gloves states that they are designed for runners, hikers, and backcountry skiers. The Stormweight glove, due to the heightened protection and surer grip that the palmside material provides as well as the marketing indicating it is designed with runners, hikers and skiers in mind, is classified in subheading 4203.21.80, HTSUS, as “gloves, mittens and mitts: specially designed for use in sports: other.”
The suede palm patch for grip and durability, silicone overlays on the fingertips for improved tactility, the “windbloc” polartec fleece shell in conjunction with marketing information and consumer reviews obtained from www.backcountry.com and www.amazon.com evidence that the Windweight glove is specially designed, marketed and sold for use in climbing and mountaineering. It is classified in subheading 6116.93.08, HTSUS, as knit gloves specially designed for use in sports.
HOLDING:
By application of GRI 3, styles 801605, 801610, 801564, 801566, 801551, 801555, 801511, 801512, 801576, 801578, 801431, and 801436 are classified in subheading 4203.21.60, HTSUS, which provides for: “Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Specially designed for use in sports: Ski or snowmobile gloves, mittens and mitts: Other.” The 2009 column one, general rate of duty is 5.5% ad valorem.
Styles 801724 and 801725 are classified in subheading 4203.21.80, HTSUS, which provides for: “Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Specially designed for use in sports: Other.” The 2009 column one, general rate of duty is 4.9% ad valorem.
Style 801060 is classified in subheading 4203.21.80, HTSUS, which
provides for: “Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Specially designed for use in sports: Other.” The 2009 column one, general rate of duty is 4.9% ad valorem.
Styles 801062 and 801063 are classified in 6116.93.08, which provides for: “Gloves, mittens and mitts, knitted or crocheted: Other: Of synthetic fibers: Other gloves, mittens and mitts, all the foregoing specially designed for use in sports, including ski and snowmobile gloves, mittens and mitts.” The 2009 column one, general rate of duty is 2.8% ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
EFFECT ON OTHER RULINGS:
New York Rulings Letters (NY) N042400, N042401, and N042402, dated November 14, 2008, are hereby modified with respect to the classification of styles 801605, 801610, 801564, 801566, 801551, 801555, 801511, 801512, 801576, 801578, 801431, 801436, 801724, 801725, and 801060.
In accordance with 19 U.S.C. §1625(c), this ruling will become effective 60 days after its publication in the Customs Bulletin.
Sincerely,
Myles B. Harmon, Director
Commercial and Trade Facilitation Division