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NY 805098

December 19, 1995

CLA-2-56:S:N:N6:351 805098


TARIFF NO.: 5609.00.3000

Mr. Robert Stankiewicz
Frank W. Winne and Son Inc.
44 North Front Street
Philadelphia, PA 19106

RE: The tariff classification of braided 8-strand, 720 foot long mooring line (rope), 8 inches in diameter with 6-foot canvas covered eyes (eye splices or loops) at either end, from Korea.

Dear Mr. Stankiewicz:

In your letter dated December 12, 1994 you requested a tariff classification ruling.

You have enclosed a photograph showing a braided 8-strand, 720 foot long mooring line (rope), 8 inches in diameter with 6-foot eyes at either end. The eyes appear to have been spliced in a permanent manner and are covered with a canvas sheath. You state that these ropes are imported specifically for mooring line use only, and that the eyes will not be removed. You have also enclosed letters from two of your customers, marine suppliers who both state:

The rope is used for mooring large vessels to the dock, the 720 foot lengths are required due to the fact that most vessels are approximately 600 ft. in length and covers the distance when mooring the vessel fore to aft to stabilize it, leaving 120 feet slack to move with the tides. Please also note the dock may be 50 feet or so from the mooring kevel on the boat requiring extra rope length.

As to the 6 foot canvas covered eye at each end of the rope. This is needed to hook onto the dock kleat and the kevel on the vessel. This 6 foot canvas covered eye is never cut off.

The Explanatory Notes to the Harmonized Tariff Schedules (HTS) constitute the official interpretation of the nomenclature at the international level. The Explanatory Notes to heading 5609 indicate that this provision includes cordage cut to length and looped at one or both ends. The mooring line at issue here is looped in a substantial way at both ends. In addition, you have provided evidence that it is cut to the length in which it will actually be used to moor vessels.

The applicable subheading for the mooring lines will be 5609.00.3000, HTS, which provides for articles of...twine, cordage, rope or cables, not elsewhere specified or included; of man-made fibers. The rate of duty will be 9 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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