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NY A82321

April 17, 1996

CLA-2-87:RR:NC:MA:101 A82321


TARIFF NO.: 8715.00.0020

Mr. Marc S. Greenberg
Executive Vice President
600 Sylvan Avenue
Englewood Cliffs, NJ 07632

RE: The tariff classification of a baby stroller/carrier from Thailand and China

Dear Mr. Greenberg:

In your letter dated April 8, 1996 you requested a tariff classification ruling on behalf of the Importer, Evenflo Company, Inc. of Piqua, Ohio.

The item concerned is the FRESH AIR GEAR combination Baby Stroller/Carrier (Item #522101). It consists of a nylon backpack-shaped Baby Carrier which can "double" as the carrier portion of a baby stroller when wheels and a frame are attached; the Carrier is colored navy blue, black and tan and measures 25" in height X 13" in width X 8" in depth. Also included are two 19" diameter, hard plastic, tan and navy blue Wheels with hard plastic, navy blue snap-on Wheel Covers; two 2«", triangular Brake Levers of red, hard plastic with one rounded end that has a small hole through it and two 4",U-shaped Connecters of black metal with holes through each end.

You state that the nylon Carrier portion of the item is manufactured in Thailand and that the Wheels, Wheel Covers, Brake Levers, Connecters and other assorted parts are manufactured in China and that they will all be imported together as unassembled parts. You further state that the aluminum tube frame portion of the completed item will be domestically manufactured.

The applicable subheading for the FRESH AIR GEAR Baby Stroller/Carrier will be 8715.00.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for Baby carriages (including strollers) and parts thereof: Baby carriages (including strollers). The rate of duty will be 4.4% ad valorem. If imported all together in a single carton, the Country of Origin Marking requirement would be "Made in Thailand and China" on the carton, itself. If packed in separate cartons, but included in the same shipment, each carton should bear it's own individual Country of Origin marking; e.g., the carton containing the Carrier should be marked "Made in Thailand", the carton with the Wheels, Wheel Covers, Brake Levers, Connecters and assorted parts should be marked "Made in China". In either circumstance, the Formal Entry documents submitted to U.S. Customs upon importation would have to include a per-Country of Origin breakdown of component parts and their respective values. The Carrier portion of the Stroller/Carrier would be listed as one item under subheading 8715.00.0020 with a Country of Origin of Thailand along with it's value and the Wheels, Wheel Covers, Brake Levers, Connecters and any other included parts would be listed as a separate item under subheading 8715.00.0020 with a Country of Origin of China and their value.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Robert DeSoucey at 212-466-5667.


Roger J. Silvestri

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