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NY 871735

March 9, 1992

CLA-2-56:S:N:N3H:351 871735


TARIFF NO.: 5607.50.2000; 9802.00.80

Ms. Mary Ellen Bryan
Rauh Rubber, Inc.
1310 DeValera Avenue
Akron, OH 44310

RE: The tariff classification of twisted rope made of scrap magnetic tape assembled in the Philippines.

Dear Ms. Bryan:

In your letter dated February 19, 1992, you requested a tariff classification ruling.

You have submitted a sample piece of twisted, 3-strand rope. The rope measures 1/2 inch in diameter and will be packaged in coils that are 200 meters in length. It may be imported in other diameters. In your letter, you stated that Rauh Rubber will supply the raw material, scrap magnetic tape edge trim manufactured in the United States, to the Philippine Synthetic Products company where they convert it into magnetic tape rope. In a phone conversation with National Import Specialist Jeffrey Konzet on February 27, 1992, you stated that the tape is sent over to the Philippines on reels and that there is no processing done in the Philippines other than twisting the material into rope. We would consider this twisting of American-made material into rope to constitute an acceptable assembly operation because it is a method used to combine or join yarns made of textile strip, which are solid components. Our New York laboratory has determined that the magnetic tape material used to make the rope is a polyester fiber, not an olefin fiber. We assume that the cordage measures more than 10,000 decitex.

The applicable subheading for the twisted rope will be 5607.50.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for twine, cordage, ropes and cables, whether or not plaited or braided and whether or not impregnated, coated, covered or sheathed with rubber or plastics, of other synthetic fibers, not braided or plaited. The rate of duty will be 15 percent ad valorem plus 27.6 cent per kilogram.

An allowance will be made for the value of the supplied American-made scrap magnetic tapes when they reenter the United States as rope. The twisting operation in the Philippines is an acceptable assembly within the purview of the provision for subheading 9802.00.80, HTS. The provision provides for articles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process such as cleaning, lubricating and painting.

The rope falls within textile category designation 201. Based upon international textile trade agreements, products of the Philippines are subject to the requirement of a visa and quota restraints in the same manner as for other imported merchandise.

The designated textile and apparel category may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Since part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes, to obtain the most current information available, we suggest that you check, close to the time of shipment, the Status Report On Current Import Quotas (Restraints Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.

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.


Jean F. Maguire
Area Director

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