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NY 883496

March 17, 1993



TARIFF NO.: 8716.90.5060

Mr. Joe Martinez
United Products Sales & Service, Inc.
P.O. Box 38
Justin, TX 76247

RE: The tariff classification of utility trailer top rails, roof bows and side stiffeners from Mexico

Dear Mr. Martinez:

In your letter dated February 22, 1993 you requested a tariff classification ruling for utility trailer top rails. You have submitted photographs of the top rails, along with pictures of utility trailers showing the roof bows and side stiffeners that you already import from Mexico.

The top rails will be used in the manufacture of utility trailers. The rails will be constructed of 14 gauge or 10 gauge by 2 3/8 inch OD tube. The rails will be precut as follows:

(Product/Photograph AA) "A" end will have a welded cap on the end and the "B" end will be open.

(Product/Photograph BB) "A" end will have a welded cap on the end and the "B" end will be saddled, to be prefitted.

(Product CC/no photograph) Both ends will have welded caps, as imported

As your photographs show, the utility trailer top rails will be cut to length with pre-welded end caps, and with prefitted or saddled ends.

You further state that you are already importing the roof bows in square tubing. These roof bows are also used in the manufacture of utility trailers. You would like to verify that the same roof bows and side stiffeners may be imported using round tubing. The bows are approximately six feet wide by six feet high. These products will be made of 10 gauge by 1 1/4 inch round tubing and they are imported arched and precut. The roof bows and side stiffeners are produced in one piece.

The applicable subheading for the utility trailer top rails, side bows and side stiffeners will be 8716.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of trailers and semi-trailers, other. The rate of duty will be 3.1 percent ad valorem.

Articles classifiable under subheading 8716.90.5060, HTS, which are products of Mexico are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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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