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NY E89148

November 16, 1999

CLA-2-76:RR:NC:1:118 E89148


TARIFF NO.: 7604.21.0000; 3916.20.0090

Mr. Thomas A. Penska
PBB Global Logistics
434 Delaware Avenue
Buffalo, NY 14202

RE: The tariff classification of window shade roller components from the United Kingdom.

Dear Mr. Penska:

In your letter dated October 13, 1999, you requested a tariff classification ruling on behalf of your client Louver-Lite.

You stated that the samples are window shade roller components made in the United Kingdom. Four of the parts are made of aluminum alloy, grade 6063-T5. Three of these parts are referred to as tubes: parts R8021, R8024 and R8027. There is one aluminum bottom bar, part R8121 and one plastic bottom bar, part R8120. All of these components are parts of a side-control roller blind or window shade system. The tubes and bottom bars are to be used with fabric of varying widths. The aluminum tubes are extruded from aluminum in the shape of hollow profiles with indentations along their entire length. The plastic bottom bar is extruded from polyvinyl (PVC) in the form of a profile shape with a complex cross-section which is also uniform throughout the length of the extrusion.

The applicable subheading for the aluminum tubes and bottom bar, parts R8021, R8024, R8027 and R8121, will be 7604.21.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for aluminum bars, rods and profiles: of aluminum alloys: hollow profiles. The general duty rate will be 1.5% ad valorem.

Consideration was given to classifying the aluminum tubes and bottom bars, in 7608.20.00, HTS, as you have suggested. However, chapter 76 Note 1(e), which defines tubes and pipes, does not describe your products. Chapter 76 Note 1(b) applies to these items as aluminum profiles.

The applicable subheading for the plastic bottom bar, part R8120 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 general duty rate will be 5.8% ad valorem.

If you wish to apply for a North American Free Trade Agreement (NAFTA) ruling for these products at a future date, additional information would be required. Specifically, a flow chart indicating all manufacturing processes in and out of the territory of Canada would be needed.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this 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 Kathy Campanelli at 212-637-7025.


Robert B. Swierupski

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