Ms. Natouchka Patrice Rampy
Sharretts, Paley, Carter & Blauvelt, P.C.
67 Broad Street
New York, N.Y. 10004
RE: The tariff classification of "Temporary Tattoo Transfers"
(printed decals) from Taiwan.
Dear Ms. Rampy:
In your letter dated May 24, 1993, on behalf of your client,
Collegeville/Imagineering (Phoenix, AZ), you requested a tariff
Samples were submitted and are being returned as requested.
They are 4 x 6 1/2 inch sheets of paper bearing different
selections of printed pictorial decalcomanias (transfers). They
are put up for retail sale, one sheet per package, in plastic bags
with printed header cards. Each package also contains a separate,
printed instruction sheet which advises the user to cut out the
design of his or her choice, place it face down on skin, dab with
a wet washcloth or towel, and peel away the paper after the image
has been transferred. The resulting "tattoo," which is said to
last several days if treated carefully, can be removed with cold
cream or rubbing alcohol.
The applicable subheading for the "Temporary Tattoo Transfers"
will be 4908.90.0000, Harmonized Tariff Schedule of the United
States (HTS), which provides for transfers (decalcomanias), other
than vitrifiable. The rate of duty will be 15.4 cents per
We note that the country of origin marking on the submitted
samples is not acceptable. The back of the header card is marked
"Made in Taiwan," but the front of the decal sheet, which shows
through the front of the package, is printed with a copyright date
followed by "Imagineering Inc., Phoenix, AZ 85061." This reference
to a U.S. address triggers the requirements of 19 CFR 134.46,
meaning that it will be necessary to place the words "Made in
Taiwan" in close proximity to "Phoenix, AZ," on the bag or decal
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
Jean F. Maguire
New York Seaport