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HQ 951840

February 9, 1993

CLA-2 CO:R:C:T 951840 CC


TARIFF NO.: 5607.49.2500

Silvia Perez
M.G. Maher & Co., Inc.
One Canal Place
Suite 2100
New Orleans, LA 70130

RE: Classification of rope; classifiable in Heading 5607

Dear Ms. Perez:

This letter is in response to your inquiry, on behalf of Twi Ro Pa Mills Agency, Inc., requesting the tariff classification of rope. Samples were submitted for examination.


Article #2 is a clean rope with an eye approximately 1 foot in diameter at one end; the eye was formed by splicing one end of the rope back on itself. The splicing appears to have done by hand after the rope was made. You indicate that this rope, which is 60 percent polypropylene and 40 percent polyester, will be sold in 600-foot lengths, in coils or reels, as anchor lines, towing lines, mooring lines, deck lines, or barge lashing lines. It will be sold through marine outlets to the fishing, towboat, and barge trades.

Article #1 is identical in construction to Article #2 except that it is lightly smudged in places, and the eye has been cut open. The exposed fibers at the cut portions of the eye have been beaded and blackened, as if a flame was held to them after cutting. The rest of the rope, although smudged, shows no damage and appears to still be usable as rope. Article #1 represents used rope that will be subject to inspection by the importer before sale. If the rope is found upon inspection to be "saleable," it will be sold through the same marine channels as for Article #2. If the rope is found to be "unfit," it will be sold through surplus and salvage dealers. It will also be sold in 600-foot lengths.


Whether the merchandise at issue is classifiable in Heading 5607 of the Harmonized Tariff Schedule of the United States Annotated (HTSUSA), Heading 5609, HTSUSA, or Heading 6310, HTSUSA?


Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes.

You believe that Article #1 is classifiable in Heading 6310, HTSUSA, which provides for used or new rags, scrap twine, cordage, rope and cables, and worn out articles of twine, cordage, rope or cables, of textile materials. The Harmonized Commodity Description and Coding System, Explanatory Notes, the official interpretation of the HTSUSA at the international level, states that Heading 6310 includes the following:

Scrap pieces of twine, cordage, rope or cables, used or unused (e.g., scrap pieces resulting from the manufacture of twine, cordage, rope or cables, or of articles thereof), and old twine, cordage, rope and cables and worn out articles of such materials.

To fall in the heading, these products must be worn, dirty or torn, or in small pieces. They are generally fit only for the recovery (e.g., by pulling) of the fibers (which are usually re-spun), for the manufacture of paper or plastics, for the manufacture of polishing materials (e.g., polishing wheels), or for use as industrial wipers (e.g., machine wipers).

The submitted sample for Article #1 is undamaged and only slightly smudged; it appears to be usable as rope. This article clearly does not meet the requirements of the Explanatory Notes for classification in Heading 6310.

Heading 5607, HTSUSA, 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. The Explanatory Notes state the following concerning this heading:

Twine, cordage, ropes and cables are used as binder twine, for tying packages, towing, loading, etc. Their cross-section is usually round but some (e.g., some transmission cables) have a square, trapezoidal or triangular section. They are normally unbleached, but may be dyed, impregnated to make them rot-proof, formed of different colored strands, or impregnated, coated, covered or sheathed with rubber or plastics.

These products are classified here whether or not cut to length.

The heading excludes:


(c) Articles of heading 56.09.

Heading 5609, HTSUSA, provides for articles of yarn, strip or the like of Heading 5404 or 5405, twine, cordage, rope or cables, not elsewhere specified or included. The Explanatory Notes to this heading state that it includes yarns, cordage, rope, etc., cut to length and looped at one or both ends, or fitted with tags, rings, hooks, etc., (e.g., shoe laces, clothes lines, towing ropes), ships' fenders, unloading cushions, rope ladders, loading slings, dish "cloths" made of a bundle of yarns folded in two and bound together at the folded end, etc.

The merchandise at issue is 1/2-inch diameter 3-strand lines which, according to your submissions, will be imported in 600- foot lengths with an eye splice at one end. You also state that these products will have various marine uses, such as anchor and deck lines. We do not believe that a 1/2-inch diameter rope of polypropylene and polyester will have direct applications in lengths of 600 feet. Such articles will most likely be cut after importation for various uses such as dock lines, towing or anchor lines. Therefore these articles have not been cut to length and are not classifiable in Heading 5609 according to the Explanatory Notes. Instead they are classifiable in Heading 5607.


Articles #1 and #2 are classified under subheading 5607.49.2500, HTSUSA, 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 polyethelene or polypropylene, other, other, not braided or plaited, other. The rate of duty is 27.6 cents per kilogram plus 15 percent ad valorem, and the textile category is 201.

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

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 (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.


John Durant, Director

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