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NY A84479

June 25, 1996

CLA-2-60:RR:NC:TP:351 A84479


TARIFF NO.: 6002.43.0080

Mr. Stephen Gould
Ford Motor Company
U.S. Customs Compliance and Operations
Regent Court Building
16800 Executive Plaza Drive
Suite 820
Dearborn, MI 48126

RE: The tariff classification of knitted vinyl fabric from Canada

Dear Mr. Gould:

In your letter dated April 26, 1996, with supplemental information sent in a letter dated May 31, 1996 you requested a tariff classification ruling.

You have submitted a sample of a warp-knitted fabric that was made in the United States, and a sample of the same fabric after further processing in Canada. The material is knitted from folded PVC strips which have an apparent width of between 1 and 2 millimeters, and which are reinforced with unidentified man-made fibers. After knitting in the United States, the fabric is sent to Canada where it is heated and then pressed between steel rolls to give it a smooth surface suitable for what you refer to as "printing." A "printer" is used to coat one side of the material with a light coating of a PVC compound; the material is then passed through an oven to dry the coating. The coating, which is not visible to the naked eye, gives the sheet a dry "hand" and cleanability. The original (U.S.) and finished (Canadian) fabric differ in appearance in that the surface of the finished fabric is noticeably flatter and duller. The material is used for stadium seats or as interior upholstery in commercial trucks; we assume that it is imported in widths greater than 30 centimeters.

The applicable subheading for the finished fabric will be 6002.43.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for other knitted or crocheted fabrics; other fabrics, warp knit...; of man-made fibers; other; other. The rate of duty will be 13.2 percent ad valorem.

You have also asked about the applicability of HTSUSA 9802.00.50, which covers "articles exported for repairs or alterations," to the processing of this fabric in Canada. The processing in Canada goes beyond what is allowed under the provision for alterations and repairs in subheading 9802.00.50. Pressing the fabric between rolls to change the texture of the surface, and coating the fabric with PVC using a printing process to change the character (washability) of the fabric, are manufacturing steps needed to finish the article for its intended special use, and are not repairs or an alterations.

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 Jeff Konzet at 212-466-5885.


Roger J. Silvestri

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