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NY D85251




December 11, 1998

CLA-2-39:RR:NC:SP:221 D85251

CATEGORY: CLASSIFICATION

TARIFF NO.: 3926.90.9880; 3916.20.0090

Ms. Maura Mc Ardle
Valpar Industrial Limited
13 Balloo Drive, Balloo Industrial Estate Bangor, CO Down BT19 2QY, Northern Ireland

RE: The tariff classification of the "DockSafe" dock bumper from the United Kingdom.

Dear Ms. Mc Ardle:

In your letter dated October 20, 1998, you requested a tariff classification ruling.

A sample segment of the DockSafe dock bumper was provided with your letter. The interior of the bumper is composed of two layers of polyethylene tubes arranged concentrically around a center tube. The polyethylene tubes are encased within a tubular cushion of closed cell foam insulation. Surrounding the foam is an exterior layer of plastic sheeting. The dock bumper is designed to be attached to the edge of a dock to provide protection to docks and boats. The foam insulation and polyethylene tubes provide a cushioning effect when a boat rams up against the dock.

The bumper is in a tubular shape with one protruding flat edge. It is designed to be fitted to the dock by sliding the flat edge into a rigid fixing rail. A sample piece of fixing rail was also included with your request. The rail is made of polyvinyl chloride (PVC), extruded roughly in a U shape with hooked edges. End caps, joiners and right angled corner pieces are available to give the appearance of a smooth continuous system all around the dock.
You have not indicated whether these products will be imported in the form of a complete, unassembled dock bumper system, or whether they will be imported in the form of bulk shipments of inventory stock from which customers may order the parts necessary to assemble a system appropriate to their individual needs.

The applicable subheading for an essentially complete, unassembled dock bumper system, including the bumpers, rails, end caps, joiners and corner pieces, as well as for bumpers, end caps, joiners and corner pieces imported separately or as inventory stock, will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the rails, imported either separately or as inventory stock, will be 3916.20.0090, HTS, which provides for 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 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 Joan Mazzola at 212-466-5580.

Sincerely,

Robert B. Swierupski
Director,

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