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NY 883422

March 25, 1993

CLA-2-84:S:N:N1:103 883422


TARIFF NO.: 8479.89.9099; 8302.49.6050; 3926.90.9090

Ms. Valerie L. Matthews
Tower Group International, Inc.
128 Dearborn Street
Buffalo, NY 14207-3198

RE: The tariff classification of a boat mooring system from Canada.

Dear Ms. Matthews:

In your letter dated March 1, 1993 on behalf of Vacuseat Systems Inc. you requested a tariff classification ruling.

The T. Bo-Lok boat mooring system is designed to fasten a pleasure boat to a dock without the use of bumpers or ropes. The system consists of two suspending arms and two boat cleats, as well as a rope adapter and clamp. These articles will normally be shipped together, but on occasion can be shipped separately. According to a letter from your client, the system will normally be sold to marine distributors and marinas.

The boat cleats are made of a plastic or stainless steel base and body, and a stainless steel cap. They contain an integral T-slot bore which will accept a specially designed quick locking clevis. The cleats are bolted to the bow and stern of a boat in the same manner as a conventional boat cleat. The suspending arm unit consists basically of the locking clevis, stainless steel cable arms, tensioner assembly, and mounting stand. Each suspending arm consists of three rods formed from high strength nylon which slide over stainless steel cables 3/16 of an inch in diameter. The arm is flexible, but becomes rigid when tension is applied to it. The clevis is attached to the end of the arm and has two locking lugs which fit into the T-slot bore in the boat cleat. The tensioner assembly houses a unique cam system which, when utilized by means of a hand operated mechanical lever, applies 1200 pounds of tension to the cables. The mounting stand allows the entire unit to be attached to a dock, and also allows the height of the arm to be adjusted to suit a variety of different boats.

The T. Bo-Lok system may be utilized from within the boat or while the operator is standing on the dock. Initially, the clevis is manually inserted into each of the boat cleats and rotated 90 degrees, thus connecting the boat to the two suspension arms. Tension is then applied to the arms, causing them to become rigid and securing the boat at a safe distance from the dock. A locking mechanism in the tensioner housing allows the tensioner assembly to be locked so that the boat cannot be removed without a key.

The plastic rope adapter and plastic rope clamp are used when mooring the boat to a dock which does not have suspending arms mounted on it. The adapter slips over the loop portion of a standard boat mooring rope and is clamped in place by the rope clamp and a stainless steel screw. The adapter allows the rope to be attached to the boat cleat.

The applicable subheading for the T. Bo-Lok system, imported in a single shipment, will be 8479.89.9099, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere...:other machines and mechanical appliances: other: other: other: other. The duty rate will be 3.7 percent ad valorem.

When imported separately, the applicable subheading for the boat cleats will be 8302.49.6050, HTS, which provides for other mountings, fittings and similar articles, and parts thereof: other: other: of iron or steel, of aluminum or of zinc: other: for aircraft, vessels and other vehicles. The duty rate will be 5.7 percent ad valorem. The applicable subheading for the rope adapter and clamp, when imported separately, will be 3926.90.9090, HTS, which provides for other articles of plastics: other: other: other., with duty at the rate of 5.3 percent ad valorem. The suspending arms, imported separately, remain classifiable in subheading 8479.89.9099, HTS.

Goods classifiable under subheadings 8479.89.9099, 8302.49.6050, and 3926.90.9090, HTS, which have originated in the territory of Canada, will be entitled to the following reduced rates of duty under the United States-Canada Free Trade Agreement (FTA) upon compliance with all applicable regulations:

Subheading Duty Rate
8479.89.9099 Free
8302.49.6050 2.8%
3926.90.9090 2.6%

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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