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NY B88776

September 10, 1997

CLA-2-66:RR:NC:WA:353 B88776


TARIFF NO.: 6601.10.0000

Mr. David A. Eisen
Seigel, Mandell & Davidson, P.C.
1515 Broadway
New York, N.Y. 10036-8901

RE: The tariff classification of a Portable Beach Umbrella from China and/or Taiwan

Dear Mr. Eisen:

In your letter dated August 22, 1997, you requested a tariff classification ruling on behalf of your client Avon Products, Inc. A sample was submitted for examination and will be returned per your request.

The submitted sample , PP 163237, is described as a portable beach umbrella with a nylon carrying case. The umbrellas, which is designed in sections, is made up of a top portion, measuring approximately 22 inches in length, which consists of the nylon umbrella top and shaft which includes the metal hardware, hinges, a push-button and automatic release. There are three poles which screw into the top portion and each other to complete the article for securing into the sand. A fitted nylon carrying case is included with a fabric tie closure. This carrying case satisfies the criteria for cases under GRI 5(a) in that it is specially shaped to contain the specific article, is suitable for long-term use, is presented with the article for which it is intended, is a kind normally sold with such article, and does not give the whole its essential character. Thus the umbrella and nylon fabric carrying case are classified together.

The applicable subheading for the Portable Beach Umbrella, PP 163237, will be 6601.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Umbrellas and sun umbrellas (including walking-stick umbrellas, garden umbrellas and similar umbrellas): Garden or similar umbrellas". The rate of duty will be 7.2 percent ad valorem.

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 Martin Weiss at 212-466-5881.


Paul K. Schwartz
Chief, Textiles and Apparel Branch

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