N348995

N348995 June 6, 2025 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification, Country of Origin; Marking TARIFF NO.: 6307.90.9891; 9903.01.24; 9903.01.25; 9903.88.15 Ms. Theresa A. Marino Euro Cargo Express 20 East Sunrise Highway Valley Stream, NY 11581 RE: The tariff classification, country of origin, and marking of shoe accessory kits from China and Italy; 19 CFR 102.21(c)(2) Dear Ms. Marino: In your letter dated May 14, 2025, you requested a ruling on the tariff classification, country of origin, and marking of shoe accessory kits on behalf of your client, Streettrend LLC DBA P448 LLC. Samples of the product were provided to this office and will be retained for training purposes. The sample described as a “Cowboy Accessories Set,” is an assortment of shoe ornaments and shoelaces designed to provide a unique look to the wearer’s shoe. The set includes a pair of 100 percent leather shoelaces, a pair of 100 percent cotton braided dyed white shoelaces, one decorative coin with a metal ring, six plastic beads, and a metal key accessory with a ring. The items come packaged in a clear and resealable plastic bag. The items are meant to be interchangeable with each other to switch the look of shoes each time they are worn. The sample described as a “Glam Accessories Set,” is an assortment of shoe ornaments and laces designed to provide a unique look to the wearer’s shoe. The pack includes one beaded plastic string shoelace, one 100 percent polyester narrow woven shoelace, and seven pieces of imitation jewelry: a “P” shaped metal accessory with rhinestones and a clasp, two star shaped metal accessories with rhinestones and clasps, a gold-colored metal bracelet with two clasps, a circular stone with a clasp, an oval stone with a clasp, and an Italian horn charm with a clasp. The items come packaged in a clear and resealable plastic bag. The items are meant to be interchangeable with each other to switch the look of shoes each time they are worn. The sample described as a “Hippy Accessories Set,” is an assortment of shoe ornaments and laces designed to provide a unique look to the wearer’s shoe. The pack includes one yellow 100 percent cotton braided shoelace, one purple 100 percent polyester braided shoelace, two metal cylinder beads, one plastic bag with nineteen lettered pieces, one metal heart charm, one plastic bag with four textile flower accessories, one blue plastic bead, and one purple plastic bead. The items come packaged in a clear and resealable plastic bag. The items are meant to be interchangeable with each other to switch the look of shoes each time they are worn. The sample described as a “Scout Accessories Set,” is an assortment of shoe ornaments and laces designed to provide a unique look to the wearer’s shoe. The pack includes one black 100 percent polyester braided shoelace, one white 100 percent polyester braided shoelace, one cylindrical plastic bead, two rectangular plastic beads, one plastic bag with four lettered pieces, two circular plastic beads, one metal coin, one red textile ribbon, and two metal disc beads. The items come packaged in a clear and resealable plastic bag. The items are meant to be interchangeable with each other to switch the look of shoes each time they are worn. The manufacturing operations for each set are as follows: COWBOY: France: • Raw leather material is shipped to Italy. Albania: • Imitation jewelry (coin, rings, key) is molded, finished, and shipped to Italy. Italy: • Hot die cast acrylic is molded and polished into plastic beads. • Leather material is cut into 59 inches to form the shoelaces. • 100 percent cotton yarn is braided to form a fabric and cut. • Plastic tips are glued onto the braided fabric to form the shoelace. • The items are packaged into the biodegradable plastic bag and shipped to the United States. Each bag contains one pair of white cotton braided shoelaces, one pair of leather shoelaces, one coin with ring, one key accessory, and six plastic beads. GLAM: China: • Imitation jewelry with rhinestones is formed into the shape of the letter “P” and shipped to Italy. • Beaded string shoelace is produced, cut, finished, and shipped to Italy. • 100 percent polyester ribbon fabric is woven and shipped to Italy. Spain: • Imitation jewelry is formed in 6 separate designs and shipped to Italy: Italian horn charm with a lobster claw clasp Oval stone with lobster claw clasp Circular stone with lobster claw clasp Bracelet with two lobster claw clasps Star shaped charm with rhinestones and a lobster claw clasp Star shaped charm rhinestones and jump ring Italy: • 100 percent polyester ribbon fabric is cut. • Plastic tips are glued on to the polyester ribbon fabric to form a shoelace. • The items are packaged into the biodegradable plastic bag and shipped to the United States. Each bag contains one beaded string shoelace, one white polyester ribbon shoelace, and one piece of each imitation jewelry item described above. HIPPY: China: • Hot die cast acrylic is molded into 19 separate pieces, painted with letters, and shipped to Italy. • Acrylic is molded into plastic beads and shipped to Spain. Spain: • Flower shaped accessories are produced and painted in 4 distinct colors (orange, black, pink, yellow). • Jump rings are sewn to each of the 4 flower accessories. • Rhinestones are glued to the pink and yellow flowers. • The 4 flower accessories are placed in a bag and shipped to Italy along with the plastic beads. Albania: • Metal heart shaped charm is molded, coated, welded to a jump ring, and shipped to Italy. Italy: • Metal cylinder bead is molded and polished. • 100 percent cotton yarn is braided to form a fabric and cut. • 100 percent polyester yarn is braided to form a fabric and cut. • Plastic tips are glued onto the braided fabric to form the shoelace. • The items are packaged into the biodegradable plastic bag and shipped to the US. Each bag contains one yellow cotton braided shoelace, one purple polyester braided shoelace, two metal cylinder beads, one plastic bag with 19 lettered pieces, one metal heart charm, one plastic bag with four textile flower accessories, one blue plastic bead, and one purple plastic bead. SCOUT: China: • Hot die cast acrylic is molded into four separate pieces and painted with letters. • Acrylic is molded into circular plastic beads. • Plastic pieces and plastic beads are shipped to Italy. Albania: • Metal imitation coin and disc beads are molded, coated, and shipped to Italy. Italy: • 100 percent polyester dyed yarn is braided to form fabric and cut. • Plastic tips are glued onto both the black and white braided fabrics to form shoelaces. • 100 percent polyester ribbon is woven, dyed red, and cut. • Hot die cast acrylic is molded and polished into cylindrical and rectangular plastic beads. • The items are packaged into the biodegradable plastic bag and shipped to the US. Each bag contains one black polyester braided shoelace, one white polyester braided shoelace, one cylindrical plastic bead, two rectangular plastic beads, one plastic bag with four lettered pieces, two circular plastic beads, one metal coin, one red ribbon, and two metal disc beads. ISSUES: What is the tariff classification, country of origin determination, and country of origin marking of the subject merchandise? CLASSIFICATION: The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN X to General Rule of Interpretation (GRI) 3(b) provides: “for the purposes of this Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of products or articles put together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards)

Section 334 of the Uruguay Round Agreements Act (“URAA”) (codified at 19 U.S.C. 3592), enacted on December 8, 1994, provides the rules of origin for textiles and apparel products for purposes of the customs laws and the administration of quantitative restrictions, unless otherwise provided by the statute, entered, or withdrawn from warehouse, for consumption on or after July 1, 1996. Section 3592 has been described as Congress’s expression of substantial transformation as it relates to textile and apparel products. Section 102.21 of the Code of Federal Regulations (19 CFR 102.21), implements the URAA. The country of origin of a textile or apparel product shall be determined by the sequential application of the general rules set forth in paragraphs (c)(1) through (5) of section 102.21. See 19 CFR 102.21(c). 

Paragraph (c)(1) states, “The country of origin of a textile or apparel product is the single country, territory, or insular possession in which the good was wholly obtained or produced.” As the subject merchandise is not wholly obtained or produced in a single country, territory or insular possession, paragraph (c)(1) of Section 102.21 is inapplicable. Paragraph (c)(2) states, “Where the country of origin of a textile or apparel product cannot be determined under paragraph (c)(1) of this section, the country of origin of the good is the single country, territory, or insular possession in which each of the foreign materials incorporated in that good underwent an applicable change in tariff classification, and/or met any other requirement, specified for the good in paragraph (e) of this section:” Paragraph (e) in pertinent part states, The following rules shall apply for purposes of determining the country of origin of a textile or apparel product under paragraph (c)(2) of this section: HTSUS Tariff shift and/or other requirements 6307.90 The country of origin of a good classifiable under subheading 6307.90 is the country, territory, or insular possession in whic