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NY 881099

December 9, 1992



TARIFF NO.: 8716.39.0090

Mr. Thomas Knauff
Knauff & Grove, Inc.
RR # 1, Box 414
Julian, PA 16844

RE: The tariff classification of a Cobra trailer from Germany

Dear Mr. Knauff:

In your letter dated November 25, 1992 you requested a tariff classification ruling. You have submitted literature describing the Cobra trailer.

The imported product is an enclosed wheeled trailer that is designed specifically for the storage and transporting of a glider (sailplane). The glider is placed indide the trailer, and the hinged top portion is then closed. Inside the trailer the glider is protected against damage. The literature states that the trailer has a low profile, a low center of gravity and an aerodynamic design to facilitate perfect road handling. The trailer can remain connected to the tow vehicle while rigging or derigging the plane.

The galvanized chassis is equipped with an extra soft rubber suspension, an axle with two wheels located at the approximate midpoint of the trailer, an overrunning brake, a parking brake, a reverse gear, an extra large support wheel in front, and high quality tires. The bottom portion of the chassis is made of aluminum, the top portion is made of either aluminum or fiberglass. Other features of the trailer include a large opening angle, tip-proof wing dollies, and an automatic locking of all sailplane parts. The Cobra trailer is attached to the towing vehicle by means of a draw/tow bar.

The Explanatory Notes to the Harmonized Tariff Schedule, which constitutes the official interpretation of the tariff at the international level, states that "this heading (87.16) covers a group of non-mechanically propelled vehicles equipped with one or more wheels and constructed for the transport of goods or persons.... The vehicles of this heading are designed to be towed by other vehicles (tractors, trucks, etc.)...." The Cobra trailer for the glider (sailplane) meets this definition.

The applicable subheading for the Cobra trailer will be 8716.39.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for other trailers and semi-trailers for the transport of goods, other. The rate of duty will be 3.1 percent ad valorem.

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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