June 17 CBP Bulletin Proposes to Revoke Ruling on Reversible Comforters
In the June 17 Customs Bulletin (Vol. 54, No. 23), CBP published notices that propose to revoke rulings and similar treatment for reversible comforters.
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Comments on Proposals Due July 17
CBP said consideration will be given to any written comments received by July 17 before taking this action. In addition, any party that has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Reversible Comforters
| Item: Reversible, dyed and printed 100% polyester comforter |
| Current: The country of origin of the comforter is India, the country in which the fabric comprising the good was dyed and printed and underwent two or more of the required finishing operations. |
| Proposed: China is the country of origin. |
| Reason: The previous analysis doesn't apply because “the dyeing and printing are mutually exclusive processes,” CBP said. Because the fabric is either dyed or printed, not both, a tariff-shift rule exception doesn't apply. “As the fabric comprising the subject comforters is manufactured in China, the country of origin is China,” the agency said. |
| Proposed for revocation: NY N306605, dated October 25, 2019 |
| Proposed new ruling: HQ H309368 |