Country of Origin of Knit to Shape Apparel Products

us-cbp-informed-compliance-afc79fd3f19038ada140d2efCountry of Origin of Knit to Shape Apparel ProductsGuidance

Published CBP guidance; operative status and applicability must be assessed from the retained publisher edition.

Informed Compliance Publication. What Every Member of the Trade Community Should Know About: Country of Origin of Knit to Shape Apparel Products

This document may qualify as a “guidance document” as set forth in Executive Order 13891 and interpretations thereof; such guidance documents are not binding and lack the force and effect of law, except as authorized by law or as incorporated into a contract. This document is being posted to this portal to provide stakeholders with useful information.

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CBP Publication Number

EO13891-OT-025

    Topics
  • Trade
  • EO 13891
What Every Member of the
Trade Community Should Know About:
Country of Origin of
Knit to Shape
Apparel Products

AN INFORMED COMPLIANCE PUBLICATION
MARCH 2006

Country of Origin of Knit to Shape Apparel Products
March, 2006

NOTICE:

This publication is intended to provide guidance and information to the trade community.
It reflects the position on or interpretation of the applicable laws or regulations by U.S.
Customs and Border Protection (CBP) as of the date of publication, which is shown on
the front cover. It does not in any way replace or supersede those laws or regulations.
Only the latest official version of the laws or regulations is authoritative.

Publication History

First Published January 1999 (as “What Every Member of the
Trade Community Should Know About: Knit to Shape Apparel Products”)
Revised March 2006

PRINTING NOTE:

This publication was designed for electronic distribution via the CBP website
(
http://www.cbp.gov) and is being distributed in a variety of formats. It was originally set
up in Microsoft Word97
®
. Pagination and margins in downloaded versions may vary
depending upon which word processor or printer you use. If you wish to maintain the
original settings, you may wish to download the .pdf version, which can then be printed
using the freely available Adobe Acrobat Reader
®
.

Country of Origin of Knit to Shape Apparel Products
March, 2006

PREFACE

On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation
Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act,
became effective. These provisions amended many sections of the Tariff Act of 1930 and
related laws.

Two new concepts that emerge from the Mod Act are “informed compliance” and “shared
responsibility,” which are premised on the idea that in order to maximize voluntary compliance
with laws and regulations of U.S. Customs and Border Protection, the trade community needs to
be clearly and completely informed of its legal obligations. Accordingly, the Mod Act imposes a
greater obligation on CBP to provide the public with improved information concerning the trade
community's rights and responsibilities under customs regulations and related laws. In addition,
both the trade and U.S. Customs and Border Protection share responsibility for carrying out
these requirements. For example, under Section 484 of the Tariff Act, as amended (19 U.S.C.
1484), the importer of record is responsible for using reasonable care to enter, classify and
determine the value of imported merchandise and to provide any other information necessary to
enable U.S. Customs and Border Protection to properly assess duties, collect accurate
statistics, and determine whether other applicable legal requirements, if any, have been met.
CBP is then responsible for fixing the final classification and value of the merchandise. An
importer of record’s failure to exercise reasonable care could delay release of the merchandise
and, in some cases, could result in the imposition of penalties.

The Office of Regulations and Rulings (ORR) has been given a major role in meeting the
informed compliance responsibilities of U.S. Customs and Border Protection. In order to
provide information to the public, CBP has issued a series of informed compliance publications
on new or revised requirements, regulations or procedures, and a variety of classification and
valuation issues.

The Tariff Classification and Marking Branch, Commercial Trade and Facilitation Division, Office
of Regulations and Rulings, has prepared this publication on Knit to Shape Apparel Products,
as part of a series of informed compliance publications regarding the classification and origin of
imported merchandise. We sincerely hope that this material, together with seminars and
increased access to rulings of U.S. Customs and Border Protection, will help the trade
community to improve voluntary compliance with customs laws and to understand the relevant
administrative processes.

The material in this publication is provided for general information purposes only. Because
many complicated factors can be involved in customs issues, an importer may wish to obtain a
ruling under Regulations of U.S. Customs and Border Protection, 19 C.F.R. Part 177, or to
obtain advice from an expert who specializes in customs matters, for example, a licensed
customs broker, attorney or consultant.

Country of Origin of Knit to Shape Apparel Products
March, 2006

Comments and suggestions are welcomed and should be addressed to the Assistant
Commissioner at the Office of Regulations and Rulings, U.S. Customs and Border Protection,
1300 Pennsylvania Avenue, NW, (Mint Annex), Washington, D.C. 20229.

Sandra L. Bell
Acting Assistant Commissioner
Office of Regulations and Rulings

Country of Origin of Knit to Shape Apparel Products
March, 2006

KNIT TO SHAPE APPAREL PRODUCTS..................................................................... 6
I. DEFINITIONS AND CUSTOMS INTERPRETATION............................................................... 7
II. ADDITIONAL QUESTIONS............................................................................................. 8
I. Self-Start Bottom............................................................................................ 9
II. Beyond a Self-Start Bottom......................................................................... 10
III. Lines of Demarcation................................................................................. 11
IV. Hoods........................................................................................................ 17
V. Shoulder Sloping........................................................................................ 17
Conclusion...................................................................................................... 18
ADDITIONAL INFORMATION...................................................................................... 19
THE INTERNET............................................................................................................. 19
CUSTOMS REGULATIONS.............................................................................................. 19
CUSTOMS BULLETIN..................................................................................................... 19
IMPORTING INTO THE UNITED STATES............................................................................ 20
INFORMED COMPLIANCE PUBLICATIONS......................................................................... 20
VALUE PUBLICATIONS................................................................................................... 21
“YOUR COMMENTS ARE IMPORTANT” ............................................................................. 22

Country of Origin of Knit to Shape Apparel Products
March, 2006

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Country of Origin of Knit to Shape Apparel Products
March, 2006

KNIT TO SHAPE APPAREL PRODUCTS

On December 8, 1994, the President signed into law the Uruguay Round
Agreements Act. Section 334 of that Act (codified at 19 U.S.C. 3592) provided statutory
rules of origin for textiles and apparel entered, or withdrawn from warehouse for
consumption, on and after July 1, 1996. On September 5, 1995, Customs published
Section 102.21 of the Customs Regulations in the Federal Register, implementing
Section 334 (60 FR 46188). Thus, as of July 1, 1996, the country of origin of a textile or
apparel product has been determined by sequential application of the general rules set
forth in paragraphs (c)(1) through (5) of Section 102.21.

Customs has sought to maintain consistency in the application of section 102.21
since the rules of origin came into force. Although Customs has been successful in
establishing sound criteria through determinations based on manufacturing processes
with respect to most textile articles, there has been some confusion with respect to
those articles referred to as “knit to shape.” As a result of many of the inquiries received
by Customs with respect to knit to shape articles, and recent developments addressing
the interpretation of “knit to shape,” this document is intended to clarify many of the
ambiguities that have arisen. Although we realize that this publication focuses, for the
most part, on knit to shape upper body garments, the principles set forth in this
document are applicable to all “knit to shape” goods.

In that respect, Customs has worked closely with many interested parties in
forming an open dialogue addressing many of the issues discussed in this document.
What has resulted is a successful collaboration of the constant communication between
Customs and the trade. This is in keeping with the spirit of the Customs Modernization
Act (December 8, 1993, Title VI of the North American Free Trade Agreement
Implementation Act, Pub. L. 103-182, 107 Stat. 2057), generally referred to as the “Mod
Act,” which is premised on the idea that in order to maximize and facilitate compliance
with Customs laws and regulations, the trade community needs to be clearly and
completely informed of its legal obligations. In essence, the Mod Act imposes a greater
obligation on both Customs and the trade to share responsibility in carrying out import
requirements.

PLEASE NOTE: This guidance is valid only for country of origin determinations
under 19 C.F.R. 102.21. It is not applicable to determining the tariff classification
of "knit-to-shape" garments identified by Statistical Note 6 to Chapter 61 of the
Harmonized Tariff Schedule of the United States (HTSUS). For those purposes,
CBP cautions importers not to rely on any definition other than that statistical
note for guidance.

Country of Origin of Knit to Shape Apparel Products
March, 2006
I. Definitions and Customs Interpretation

The relevant provision in the Customs Regulations which defines “knit to shape”
is section 102.21(b), which states, in relevant part:

(3) Knit to shape. The term knit to shape applies to any good of which
50 Percent or more of the exterior surface area is formed by major parts that
have been knitted or crocheted directly to the shape used in the good, with no
consideration being given to patch pockets, appliques, or the like. Minor cutting,
trimming, or sewing of those major parts will not affect the determination of
whether a good is “knit to shape.”

(4) Major parts. The term major parts means integral components of a good
but does not include collars, cuffs, waistbands, plackets, pockets, linings,
paddings, trim, accessories, or similar parts.

In applying this provision to knit to shape articles, Customs has held that a major
knit garment panel which is stated to be “knit to shape” but is not contoured at critical
points like the neck and armholes, does not qualify as a knit to shape panel. As such, in
those cases where, for example, a front or back panel is cut to shape at the neck or
armholes, Customs has concluded that the panel is not knit to shape, as per the terms
of section 102.21(b). However, as a caveat to this rule, Customs has indicated that
where a knit garment consists of, for example, a front panel that is not determined to be
knit to shape, but a back panel and sleeves that do qualify as knit to shape panels, the
garment as a whole qualifies as a knit to shape good. The rationale being that as per
the definition of “knit to shape” in section 102.21(b), the term knit to shape applies to
any good of which 50 percent or more of the exterior surface is formed by major parts
that have been knitted or crocheted directly to shape. Accordingly, in that situation, that
is, where the back panel and sleeves are major parts which constitute “50 percent or
more” of the exterior surface of the good, the article qualifies as a knit to shape good.

Headquarters Ruling Letter 960871, dated November 24, 1997, addressed the
country of origin of two styles of women’s knit pullovers that featured among other
things, one style which had front and back panels which as knit, were fully contoured at
the armholes, side seams, shoulders and bottom, requiring cutting at the neck along the
lines of demarcation, and a second style with front and back panels with lines of
demarcation at the neck and armholes and sleeve panels knit with lines of demarcation
at the armholes. The type of lines of demarcation in those garments included a subtle
change in the knit fabric, i.e., from a two by two rib to a two by one rib, and a series of
small holes, both types forming semi-circular patterns as an indication of where the
cutting would take place. In that ruling, Customs stated that “regardless of how the lines
of demarcation are fashioned, the fact remains that without subsequent cutting

Page -7-

Country of Origin of Knit to Shape Apparel Products
March, 2006
operations, the garments would either lack a neck opening or arm openings. As such,
the cutting to shape of the panel to form the neck contour or the cutting to shape at the
sleeves to form the armholes goes beyond the “minor cutting” envisioned by section
102.21(b).” Consequently, both garments in HQ 960871 were not considered “knit to
shape.”

Subsequent to the issuance of that ruling, Customs interpretation of “knit to
shape,” particularly with respect to its position on “lines of demarcation,” was called into
question. In response to these concerns, Customs revisited its position on “knit to
shape” and “lines of demarcation.” In HQ 960516, dated July 14, 1998, Customs issued
the first ruling on a knit to shape good which in effect softened its position on those two
critical issues. That ruling was followed by HQ 961828, dated July 27, 1998, and HQ
961981, dated September 3, 1998, both of which served to clarify Customs
interpretation of “knit to shape” expressed in HQ 960516. Simply stated, the rationale in
those three rulings addressed lines of demarcation in panels and basically confirmed
that, in Customs view, if a garment panel featured:

a. lines of demarcation which are continuous, with clear starting and ending
points, thus, “clear and unambiguous” lines of demarcation; and

b. the lines are created by a change in pattern which is knit directly into the
fabric; and

c. a self-start bottom

the garment panel is considered “knit to shape.” Of course, a panel with a self-start
bottom and which is knit directly to shape on the knitting machine, that is, with the
neckline and arm holes formed during the knitting process, also qualifies as knit to
shape.

II. Additional Questions

Further guidance was requested in terms of clarification on a number of issues
which had either not been addressed or required further detail. In order to facilitate this
clarification process between Customs and the trade, several interested parties
submitted a number of knit garment panels as examples of certain construction
methods which exist in the apparel industry. By reviewing those samples and providing
feedback, it is Customs belief that such guidance will enable importers to more fully
comprehend the origin implications of the various construction methods used in knit
goods.

Page -8-

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Page -9-
I. Self-Start Bottom

Is a “Self-Start bottom” a prerequisite
for a knit to shape panel?
Yes. A Self-Start bottom is a prerequisite for a
knit to shape front, back or sleeve panel.
How does Customs define a “Self-
Start bottom”?
Customs defines “Self-Start bottom” as a
finished bottom edge which is the beginning of
a continuously knit garment. As such, the
edge is finished when it comes off the
machine. Similarly, sleeves must exhibit the
same type of self-start end, usually at the
bottom of the sleeve or cuff. The sleeve
panels should be either shaped or feature
acceptable lines of demarcation.

Knit to Shape Apparel Products
March 2006

II. Beyond a Self-Start Bottom

If a panel has a self-start
bottom, what else does it need
to qualify as “knit to shape”?
If a front or back panel features a self-start bottom,
either the armholes or the neck hole must be shaped
or marked with clearly acceptable lines of
demarcation. As further clarification we would add
the following examples:
A. A square panel with a self-start bottom and
no shaping at either the neck or armhole is
not knit to shape.
B. A panel with a self-start bottom and
shaping only at the neck is knit to shape.
C. A panel with a self-start bottom and clear
lines of demarcation at the neck is knit to
shape
D. A panel with a self-start bottom and
shaping only at the arm holes is knit to shape
E. A panel with a self-start bottom and clear
lines of demarcation at the arm holes is knit
to shape.
F. A panel with a self-start bottom and
shaping at the neck and clear lines of
demarcation at the arm holes is knit to shape.
G. A panel with a self-start bottom and clear
lines of demarcation at the neck and shaping
at the armholes is knit to shape.
Can several panels knit
directly in a blanket of fabric
with lines of demarcation
separating each of the panels
from one another, still be
considered knit to shape?
Yes. So long as the lines of demarcation separate
both the individual panels by clear and continuous
lines of demarcation and each panel within the
blanket of fabric meets the requirements for
acceptable lines of demarcation at either the neck,
armholes or sleeves.

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Knit to Shape Apparel Products
March 2006

III. Lines of Demarcation

Comment Response
How does Customs define an
acceptable line of demarcation?
Customs definition of an acceptable line of
demarcation is a clearly visible change in knit pattern
which is knit directly into the fabric, is continuous, and
has clear starting and ending points.
Would the following lines of
demarcation qualify as
acceptable under Customs
definition?
We emphasize that the technical terminology
(appearing in “underlines”) that follows in
examples A through E, are taken from
submissions of actual samples received by
Customs. They should in no way be taken to
represent terminology which has been adopted by
Customs in determining knit to shape panels.
Terminology will vary from manufacturer to
manufacturer.

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Knit to Shape Apparel Products
March 2006

Comment: A. Referred to as “Links-Links with Jersey Needle” lines of
demarcation knit into the fabric as in the arm hole opening lines

Response: A. The “links links with jersey needle” lines of demarcation,
which in effect consist of a change in the knit pattern construction
along the arm hole openings, with clear and continuous starting
and ending points, qualify as acceptable.

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Knit to Shape Apparel Products
March 2006

Comment: B. Referred to as “Floating Jacquard with Drop Needle” lines of
demarcation at the neck opening

Response: B. The “floating jacquard with drop needle” lines of demarcation,
which in effect consist of a change in the knit pattern construction
along the neck opening in a semi-circular pattern, with clear and
continuous starting and ending points, qualify as acceptable.

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Knit to Shape Apparel Products
March 2006

Comment: C. Referred to as “Half Milano with Pointelle” lines of
demarcation at the arm hole openings

Response: C. The “half milano with pointelle” lines of demarcation which in
effect consist of a series of holes knit along the arm hole
openings, with clear and continuous starting and ending points,
qualify as acceptable

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Knit to Shape Apparel Products
March 2006

Comment: D. Referred to as “Aran Cable Texture with Reverse Jersey”
lines of demarcation at the neck and armhole openings
Response: D. The “aran cable
texture with reverse jersey” lines of
demarcation which in effect consist of a
change in the knit pattern construction
along the neck and arm hole openings
pose a problem. Where the lines of
demarcation are located around the
neck opening, it is Customs view that
those lines are unambiguous,
continuous, and provide clear starting
and ending points. The contour that is
created by those lines is readily
apparent and has the appearance of a
clear semi-circular pattern which has
been blocked for cutting. As such, the
lines of demarcation at the neck
qualify. What is referenced as “lines of
demarcation” along the arm hole
openings however, do not meet
Customs definition. Although the
construction of those “lines of
demarcation,” represent a change in
the knit construction, it is Customs
position upon examination of that
panel, that the lines are ambiguous
and lack a readily identifiable start and
end point. It is difficult to distinguish
what is referred to as “lines of
demarcation” from the actual design
pattern of the panel. As such although
the panel itself would qualify as a knit
to shape panel because of the
presence of acceptable lines of
demarcation at the neck, were that
panel to feature only what is referred to
as “lines of demarcation at the arm
hole openings,” the panel would then
be precluded from consideration as a
knit to shape panel.

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Knit to Shape Apparel Products
March 2006

Comment: E. Referred to as “Jacquard with Change in Color” lines of
demarcation at the arm hole openings

Response: E. The “jacquard with change in color” lines of demarcation
which in effect consist of a change in the color on the panel
around the arm hole openings do not qualify as acceptable lines
of demarcation. The change in color is not a change which is knit
directly into the fabric, as for example a change in the knit
construction. Additionally, it is Customs position that a change in
color is not a clear and unambiguous line of demarcation with
clear starting and ending points particularly because this change
in color can easily be viewed as a simple function of color/pattern
in the scheme of fashion and design.

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Knit to Shape Apparel Products
March 2006

IV. Hoods

Comment Response
Does Customs view a hood as
a “major part” of a sweater
which also must be taken into
consideration for purposes of
origin?
No. It is Customs position that the term “major parts”
encompasses only the front, back and sleeve panels
and does not include a hood.

V. Shoulder Sloping.

Comment Response
Does the process of “shoulder
sloping” disqualify a part from
being considered knit to
shape?
No. The process referred to as “shoulder sloping”
has been described to Customs by some importers
as follows:
Front and back sweater panels, which are
otherwise knit to shape under Customs
current definition may have unfinished jersey
edges at the shoulders. The front and back
panels are joined together at the shoulders by
linking/looping at an angle to conform to the
wearer’s shoulders. The excess triangular
wedge of material that is created on the
inside of the shoulders can be overlock
stitched at the ends with a slight trimming
(approximately ¼ inch), leaving an excess
(also referred to as a “butterfly seam”). In the
alternative, the overlock stitching machine
can trim a slightly larger amount of material
as it sews (approximately about ½ inch).
It is Customs position that shoulder sloping
does not disqualify a panel from being knit to
shape.

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Knit to Shape Apparel Products
March 2006

V. Shoulder Sloping.

Comment Response
Does the process of working
the sleeve caps disqualify a
part from being considered knit
to shape?
No. The process of working the “sleeve caps” has
been described to Customs by some importers as
follows:
Similar to the process of shoulder sloping, the
trimming of the excess material around the
cap or shoulder area of the sleeve panel.
In Customs view this trimming of excess
material does not disqualify the panels from
being considered a knit to shape panel.

Conclusion

In conclusion, this document should not be viewed as an exhaustive
representation of all of the issues which may be associated with “knit to shape”
garments. This document does however represent Customs attempt to clarify a number
of outstanding issues on Customs interpretation of that term. We emphasize the fact
that the information provided in this publication is for general information purposes only.
To obtain an accurate origin determination reflective of the specific facts and
circumstances which surround a specific importation, an importer should submit both a
completed garment and the requisite panels as they come off the machine to obtain a
binding ruling under the Customs Regulations, 19 CFR Part 177. If samples are not
provided/submitted at the time of the ruling request, Customs may request samples
before issuing a ruling. Requests may be sent to the Director, National Commodity
Specialist Division, U.S. Customs Service, Att: Classification Ruling Requests, 6 World
Trade Center, New York, NY, 10048, or Office of Regulations and Rulings, Commercial
Rulings Division, U.S. Customs Service, 1300 Pennsylvania Avenue, N.W.,
Washington, DC 20229.

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ADDITIONAL INFORMATION

The Internet

The home page of U.S. Customs and Border Protection on the Internet’s World Wide
Web, provides the trade community with current, relevant information regarding CBP
operations and items of special interest. The site posts information -- which includes
proposed regulations, news releases, publications and notices, etc. -- that can be
searched, read on-line, printed or downloaded to your personal computer. The web site
was established as a trade-friendly mechanism to assist the importing and exporting
community. The web site also links to the home pages of many other agencies whose
importing or exporting regulations that U.S. Customs and Border Protection helps to
enforce. The web site also contains a wealth of information of interest to a broader
public than the trade community. For instance, on June 20, 2001, CBP launched the
“Know Before You Go” publication and traveler awareness campaign designed to help
educate international travelers.

The web address of U.S. Customs and Border Protection is
http://www.cbp.gov

Customs Regulations

The current edition of Customs Regulations of the United States is a loose-leaf,
subscription publication available from the Superintendent of Documents, U.S.
Government Printing Office, Washington, DC 20402; telephone (202) 512-1800. A
bound, 2003 edition of Title 19, Code of Federal Regulations, which incorporates all
changes to the Regulations as of April 1, 2003, is also available for sale from the same
address. All proposed and final regulations are published in the Federal Register, which
is published daily by the Office of the Federal Register, National Archives and Records
Administration, and distributed by the Superintendent of Documents. Information about
on-line access to the Federal Register may be obtained by calling (202) 512-1530
between 7 a.m. and 5 p.m. Eastern time. These notices are also published in the
weekly Customs Bulletin described below.

Customs Bulletin

The Customs Bulletin and Decisions (“Customs Bulletin”) is a weekly publication that
contains decisions, rulings, regulatory proposals, notices and other information of
interest to the trade community. It also contains decisions issued by the U.S. Court of
International Trade, as well as customs-related decisions of the U.S. Court of Appeals
for the Federal Circuit. Each year, the Government Printing Office publishes bound
volumes of the Customs Bulletin. Subscriptions may be purchased from the
Superintendent of Documents at the address and phone number listed above.

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Importing Into the United States

This publication provides an overview of the importing process and contains general
information about import requirements. The February 2002 edition of Importing Into the
United States contains much new and revised material brought about pursuant to the
Customs Modernization Act (“Mod Act”). The Mod Act has fundamentally altered the
relationship between importers and U.S. Customs and Border Protection by shifting to
the importer the legal responsibility for declaring the value, classification, and rate of
duty applicable to entered merchandise.

The February 2002 edition contains a section entitled "Informed Compliance." A key
component of informed compliance is the shared responsibility between U.S. Customs
and Border Protection and the import community, wherein CBP communicates its
requirements to the importer, and the importer, in turn, uses reasonable care to assure
that CBP is provided accurate and timely data pertaining to his or her importation.

Single copies may be obtained from local offices of U.S. Customs and Border
Protection, or from the Office of Public Affairs, U.S. Customs and Border Protection,
1300 Pennsylvania Avenue NW, Washington, DC 20229. An on-line version is
available at the CBP web site. Importing Into the United States is also available for
sale, in single copies or bulk orders, from the Superintendent of Documents by calling
(202) 512-1800, or by mail from the Superintendent of Documents, Government Printing
Office, P.O. Box 371954, Pittsburgh, PA 15250-7054.

Informed Compliance Publications

U.S. Customs and Border Protection has prepared a number of Informed Compliance
publications in the “What Every Member of the Trade Community Should Know
About:...” series. Check the Internet web site http://www.cbp.gov for current
publications.

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Knit to Shape Apparel Products
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Value Publications

Customs Valuation under the Trade Agreements Act of 1979 is a 96-page book
containing a detailed narrative description of the customs valuation system, the customs
valuation title of the Trade Agreements Act (§402 of the Tariff Act of 1930, as amended
by the Trade Agreements Act of 1979 (19 U.S.C. §1401a)), the Statement of
Administrative Action which was sent to the U.S. Congress in conjunction with the TAA,
regulations (19 C.F.R. §§152.000-152.108) implementing the valuation system (a few
sections of the regulations have been amended subsequent to the publication of the
book) and questions and answers concerning the valuation system. A copy may be
obtained from U.S. Customs and Border Protection, Office of Regulations and Rulings,
Value Branch, 1300 Pennsylvania Avenue, NW, (Mint Annex), Washington, D.C. 20229.

Customs Valuation Encyclopedia (with updates) is comprised of relevant statutory
provisions, CBP Regulations implementing the statute, portions of the Customs
Valuation Code, judicial precedent, and administrative rulings involving application of
valuation law. A copy may be purchased for a nominal charge from the Superintendent
of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-
7054. This publication is also available on the Internet web site of U.S. Customs and
Border Protection.

The information provided in this publication is for general information
purposes only. Recognizing that many complicated factors may be
involved in customs issues, an importer may wish to obtain a ruling under
CBP Regulations, 19 C.F.R. Part 177, or obtain advice from an expert
(such as a licensed Customs Broker, attorney or consultant) who
specializes in customs matters. Reliance solely on the general
information in this pamphlet may not be considered reasonable care.

Additional information may also be obtained from U.S. Customs and Border Protection
ports of entry. Please consult your telephone directory for an office near you. The
listing will be found under U.S. Government, Department of Homeland Security.

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March 2006

“Your Comments are Important”

The Small Business and Regulatory Enforcement Ombudsman and 10 regional
Fairness Boards were established to receive comments from small businesses about
Federal agency enforcement activities and rate each agency’s responsiveness to small
business. If you wish to comment on the enforcement actions of U.S. Customs and
Border Protection, call 1-888-REG-FAIR (1-888-734-3247).

REPORT SMUGGLING 1-800-BE-ALERT OR 1-800-NO-DROGA

Visit our Internet web site: http://www.cbp.gov

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