Mr. Miguel Ruiz
Miami International Forwarders
P.O. Box 523730
Miami, FL 33152-3730
RE: The tariff classification of button covers from Guatemala.
Dear Mr. Ruiz:
In your letter dated October 20,1993, on behalf of Bel Air
Tool Corp., you requested a classification ruling.
You have submitted a sample of six button covers on a card.
The card states "An Official Looney Tunes Product, Button Covers."
Each of the six button covers represents a cartoon character.
You state that the button covers are made of zinc and are
painted with epoxy. You also state that they are 100% USA
materials. You do not state, however, the processing that has been
done in Guatemala.
The applicable subheading for the button covers will be
9606.22.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for button...of base metal, not covered with
textile. The duty rate will be 3.6 percent ad valorem.
Articles classifiable under subheading 9606.22.0000, HTS,
which are products of Guatemala are entitled to duty free treatment
under the Generalized System of Preferences (GSP) upon compliance
with all applicable regulations.
You also ask about the marking of this item. We presume that
the button covers will be imported like the sample, six button
covers to a card. Since the button covers appear to be sold to the
ultimate consumer on the card to which they are attached, the front
of the card should be marked with the country (Made in Guatemala).
The back of the card contains the name of the trademark owner.
No geographical designation appears on the back of the card (i.e.
USA). The country of origin, therefore, does not have to be placed
on the back of the card.
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