NY 865246: The tariff classification and country of origin marking of a coin purse from China

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.

                                   NY 865246
                                 August 13, 1991

CLA-2-42:S:N:N3G:341 865246 

CATEGORY:  Country of Origin Marking

TARIFF NO.: 4202.32.2000

Mr. Marc S. Greenberg
Vice President
American Shipping Company
600 Sylvan Avenue
P.O. Box 1486
Englewood Cliffs, N.J. 07632

RE:  The tariff classification  and country of origin marking of 
a coin purse from China

Dear Mr Greenberg:

     In your letter dated July 17, 1991, you requested a ruling
as to the proper country of origin marking for a coin purse
imported in bulk.  Your request is on behalf of Topline Products
Co. Inc.

     A sample of a Polyvinyl Chloride (PVC) coin purse has been
submitted.  The item is a coin purse and is manufactured by
cutting PVC sheeting material to shape and heat sealing the
edges.  It is closed by means of a base metal snap frame which is
crimped to the top edge of the purse.  The sample is packed in a
blister pack with a lip gloss.  The reverse side of the blister
pack is printed with various literature and information including
the legend "Change Purse made in China.  All else made in USA." 
The origin information appears immediately above and in
comparable print as the United States name and address of the
distributor.     

     The applicable subheading for the coin purse will be
4202.32.2000, Harmonized Tariff Schedule of the United States
(HTS), which provides for articles normally carried in the pocket
or in the handbag, with outer surface of plastic sheeting, other. 
The duty rate will be 20 percent ad valorem. 

     You have indicated that, due to the heat sealing process,
the item cannot be permanently and conspicuously  marked with the
country of origin as provided by Section 304, Tariff Act 1930, as
amended.  In addition, you have indicated that the blister pack
marking would be sufficient to comply within the marking
requirements.   


                                  -2-

     If imported in bulk and it is to be repacked in the United
States, the purse would be subject to Customs Regulation 134.26
which provides for imported articles repacked or manipulated.  A
copy of the regulation is enclosed with this reply.  This office
would accept the sample marking as satisfying the regulation. 

    In the absence of regulation compliance, each purse must be
properly marked with the country of origin.  It is recommended
that a legible label be placed in a conspicuous location along
the interior top portion and affixed to the purse in the same
manufacturing process as when the frame is crimped.    

    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
transaction.



                                                  Sincerely,

                                   
  
                                                  Jean F. Maguire
                                                  Area Director
                                                  New York Seaport