HQ 951748: Country of origin for garments manufactured in Singapore and Malaysia

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                            HQ 951748

                          June 2, 1992

CLA-2.CO:R:C:T 951748 jlj

CATEGORY: Classification

Mr. J. M. Mok
Deputy General Manager/Director
Euro Asia Industries (S) Pte Ltd.
66 Tannery Lane
#01-03 Sindo Building
Singapore 1334

RE: Country of origin for garments manufactured in Singapore and
    Malaysia

Dear Mr. Mok:

     In your letter of March 24, 1992, you requested country of
origin rulings for garments to be produced in Singapore, with
some assembly work to be done in Malaysia.

     For country of origin purposes, Section 12.130 of the
Customs Regulations (19 CFR 12.130) is applicable to textile
articles.  Section 12.130 (b) of the Customs Regulations provides
that a textile product that is processed in more than one country
or territory shall be a product of that country or territory
where it last underwent a substantial transformation.  A textile
product will be considered to have undergone a substantial
transformation if it has been transformed by means of substantial
manufacturing or processing operations into a new and different
article of commerce.

     Section 12.130(d) of the Customs Regulations sets forth
criteria in determining whether a substantial transformation of a
textile product has taken place.  This regulation states that
these criteria are not exhaustive; one or any combination of
criteria may be determinative, and additional factors may be
considered.

     Section 12.130(d) (1) states that a new and different
article of commerce will usually result from a manufacturing or
processing operation if there is a change in:

     (i) Commercial designation or identity,
     (ii) Fundamental character or
     (iii) Commercial use.

     Section 12.130(d) (2) of the Customs Regulations states that
in determining whether merchandise has been subjected to
substantial manufacturing or processing operations, the following
will be considered:

     (i) The physical change in the material or article as a
     result of the manufacturing or processing operations in each
     foreign territory or country, or insular possession of the
     U. S.

     (ii) The time involved in the manufacturing or processing
     operations in each foreign territory or country, or insular
     possession of the U. S.

     (iii) The complexity of the manufacturing or processing
     operations in each foreign territory or country, or insular
     possession of the U. S.

     (iv) The level or degree of skill and/or technology required
     in the manufacturing or processing operations in each
     foreign territory or country, or insular possession of the
     U. S.

     (v) The value added to the article or material in each
     foreign territory or country, or insular possession of the
     U. S., compared to its value when imported into the U. S.

     Accordingly, if you wish to receive a country of origin
ruling, you should submit detailed information concerning the
manufacturing and processing operations performed in each country
to create the merchandise.  In addition, please submit a sample
of the merchandise.

     If you wish to receive a ruling concerning the country of
origin of merchandise, please submit a request, containing the
information requested, to the following address:

     Mr. John Durant
     Director
     Commercial Rulings Division
     U. S. Customs Service
     1301 Constitution Ave., N. W.
     Washington, D. C. 20229.

                                   Sincerely,



                                   John Durant, Director