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HQ 083199

March 23, 1990

CLA-2 CO:R:C:G 083199 CRS


TARIFF NO.: 5911.90.0000

Mr. Raymond A. Valdes
Customs Specialist
Ricoh Corporation
5 Dedrick Place
West Caldwell, NJ 07006

RE: Photocopier machine components of felt/nonwoven construction.

Dear Mr. Valdes:

This is in reply to your letter dated November 2, 1988, to our New York office, in which you requested a classification ruling under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). Samples were submitted with your request.


The articles in question are sixteen photocopier machine components of textile materials. The components are of felt/nonwoven construction and consist of the following:

1. Felt seal toner, part no. 54423214, of 60 percent polyol, 40 percent polyasoctaminate;

2. Felt manual feed, part no. G0034089, of 50 percent nylon, 50 percent rayon;

3. Felt-first mirror, part no. 54031699, of 60 percent wool, 40 percent rayon;

4. Oil pan felt, part no. 54424161, of 80 percent wool, 20 percent rayon;

5. Felt seal-screw, part no. 52053180, of 80 percent wool, 20 percent rayon;

6. Felt washer, part no. 54333453, of 80 percent wool, 20 percent rayon;

7. Felt, base, carriage, part no. 87912028, of 100 percent wool.

8. Felt-oil bottle, part no. 54204067, of 80 percent wool, 20 percent rayon;

9. Felt damper, part no. 54341692, of 100 percent wool;

10. Felt seal, part no. 54203079, of 85 percent polyurethane foam, 15 percent polyester film;

11. Felt seal - vibrator shaft, part no. 54463118, of 60 percent polyol, 40 percent polyasociaminate;

12. Felt - 18mm, part no. 54153096, of 80 percent wool, 20 percent rayon;

13. Felt seal - 3 x 7 x 15mm, part no. 54463497, of 85 percent wool, 15 percent rayon;

14. Felt wick, part no. 54474198, of 75 percent wool, 20 percent rayon, 5 percent oil;

15. Oil felt, part no. 54204127, of 100 percent polyamide;

16. Felt damper, part no. 52011822, fiber breakdown not provided.

The parts in question are manufactured in Japan.


Whether the articles in question are parts and accessories of photocopying apparatus of heading 9009, HTSUSA, or textile articles of a kind used for technical purposes of heading 5911, HTSUSA.


Articles are classified under the HTSUSA in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of articles is determined according to the terms of the headings and any relative section or chapter notes and, provided the headings or notes do not otherwise require, according to the remaining GRIs taken in order.

Heading 9009, HTSUSA, covers photocopying apparatus and parts and accessories thereof. However, Note 1(a), Chapter 90, HTSUSA, excludes textile articles of a kind used in machines (heading 5911) from classification in Chapter 90.

Heading 5911, HTSUSA, covers textile products and articles for technical uses. Note 7(b), Chapter 59, provides in pertinent part that heading 5911 applies to:

(b) Textile articles of a kind used for technical purposes (for example, textile fabrics and felts, endless or fitted with linking devices, of a kind used in papermaking or similar machines (for example, for pulp or asbestos-cement) gaskets, washers, polishing discs and other machinery parts).

The articles in question are of a class or kind with those described in Note 7(b), Chapter 59, and are therefore classifiable in heading 5911, HTSUSA.


The articles in question are classifiable under subheading 5911.90.0000 under a provision for textile products and articles for technical uses..., other, and are dutiable at a rate of 7.5 percent ad valorem.

Due to the changeable nature of the statistical annotation (the ninth and tenth digits of the classification) and the restraint (quota/visa) categories, you should contact your local Customs office prior to importation of this merchandise to determine the current status of any import restraints or requirements.


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