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NY K82468

January 30, 2004
CLA-2-85:RR:NC:N1:113 K82468


TARIFF NO.: 8509.80.0080

Mr. Matthew Leader
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 399 Park Avenue, 25th floor
New York, NY 1022-4000

RE: The tariff classification of a Robomop from China

Dear Mr. Leader:

In your letter dated January 13, 2003, on behalf of Telebrands Corporation, you requested a tariff classification ruling.

The sample you submitted is called the Robomop. It is an automatic floor-cleaning device for the home. The Robomop consists of a circular, plastic frame, disposable, viscose dust cloths, and a spherical drive mechanism. The dust cloth is fastened to the bottom of the frame. The drive mechanism is a plastic ball containing a weight that moves inside the ball by means of a motorized drive gear. The gear is powered by an internal rechargeable battery. The Robomop moves in a random pattern cleaning the floor as the momentum of the weight causes the ball to roll within the plastic framework. The unit will be sold with a supply of dust cloths and a 1.2 volt battery charger. You suggest classification of the Robomop as a floor polisher under 8509.20.0000, HTS. However, there is nothing in your descriptive literature that indicates the item is specifically used to polish a floor.

The applicable subheading for the Robomop will be 8509.80.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for electromechanical domestic appliances, with self-contained electric motor, other appliances, other. The rate of duty will be 4.2 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 James Smyth at 646-733-3018.


Robert B. Swierupski

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