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NY C88545

June 25, 1998

CLA-2-46:RR:NC:SP:230 C88545


TARIFF NO.: 4602.10.8000; 5702.52.0000; 5602.10.9090; 3916.20.0090; 3926.90.9880

Mr. Clark Dexter Griffith

448 W. 16th Street (4th floor)

New York, N.Y. 10011

RE: The tariff classification of "tatami flats" (floor mats) and accessories from Japan.

Dear Mr. Griffith:

In your letter dated May 27, 1998, you requested a tariff classification ruling. Samples were submitted and will be retained for reference.

The items in question are two types of floor covering products known as "tatami flats," plus related installation accessories. The floor covering will be imported in boxes containing 10 precut mats, each approximately 3' x 6'. The accessories will be boxed separately.

The version "A" mat consists of a dense, interwoven array of rushes (natural, grass-like plant material) permanently affixed to a perforated plastic-foam underlay sheet. The face layer of rushes is about 2 1/2 mm thick, while the foam underlay is about 4 mm thick.

The applicable subheading for the version "A" rush mats will be 4602.10.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for other (non-enumerated) articles of vegetable plaiting materials. The rate of duty will be 2.3%.

You asked whether the version "A" mats may be imported into the United States without being fumigated. This question should be directed to the U.S. Department of Agriculture at the following location:



4700 River Road, Unit 136

Riverdale, MD 20737-1236

The version "B" mat has a top layer of PVC plastic imitation rushes which have been woven together. Again, the top layer is permanently affixed to a plastic-foam underlay sheet. The individual plastic "rushes" are rod-like pieces, approximately 1.2 mm in apparent width (cross-section diameter), which appear to have been made by rolling or similarly processing very thin strips of plastic into that form. As such, they are considered to be textile products (rather than monofilament plaiting materials) for tariff purposes.

The applicable subheading for the version "B" PVC imitation rush mats will be 5702.52.0000, HTS, which provides for other textile floor coverings, woven, not tufted or flocked, ... not of pile construction, not made up: of man-made textile materials. The rate of duty will be 5.1%.

The version "B" mats fall within textile category designation 665. Based upon international textile trade agreements, products of Japan are subject to the requirement of a visa.

The next item is identified as a "second sheet underlay (filler)" intended to be placed on the floor underneath either of the above-described mats. It is a needleloom felt of polyester man-made fibers, and will be imported in sheets of the same size as the mats.

The applicable subheading for the "second sheet underlay (filler)" will be 5602.10.9090, HTS, which provides for other needleloom felt and stitch-bonded fiber fabrics. The rate of duty will be 11.7%.

The "second sheet underlay (filler)" falls within textile category designation 223. Based upon international textile trade agreements, products of Japan are subject to the requirement of a visa.

The designated textile categories may be subdivided into parts. If so, visa requirements applicable to the subject merchandise may be affected. Part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes. To obtain the most current information available, we suggest that you check, close to the time of shipment, the Status Report on Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.

The next items are plastic (PVC) "tracks" designed to be placed around the perimeter of the mats. These tracks are in the form of profile shapes having a uniform cross section throughout their length.

The applicable subheading for the PVC tracks will be 3916.20.0090, HTS, which provides for monofilament of which any cross-sectional dimension exceeds 1 mm, rods, sticks and profile shapes, whether or not surface-worked but not otherwise worked, of plastics: of polymers of vinyl chloride...other. The rate of duty will be 5.8%.

The next items are type "A" borders, which are fabric-covered PVC plastic pieces designed to snap onto the top of the tracks described above. The borders are in the form of profile shapes extruded from plastics and then wrapped on the top surface (and extending around the sides) with cotton fabric.

The applicable subheading for the type "A" borders will be 3926.90.9880, HTS, which provides for other (non-enumerated) articles of plastics. The rate of duty will be 5.3%.

The last items are type "B" borders, which are said to be composed of PVC and polypropylene. Since a sample of this product was not submitted, we are unable to rule on it at this time. If you wish to pursue the matter, please submit a sample, a component breakdown by weight and value, and a description of the manufacturing process indicating whether the polypropylene is added as a separate step after extrusion, or whether there are any other manufacturing steps after extrusion.

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 Paul Garretto at 212-



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