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HQ 968058

March 16, 2006



TARIFF NO.: 6111.30.5050

Maria Borges
Import Trade Coordinator
Hasbro, Inc.
200 Narragansett Park Drive
Pawtucket, RI 02862-0200

RE: Classification of Piggie Play Foot Rattle

Dear Ms. Borges:

This letter is in reply to your correspondence of December 22, 2005 in which you requested a binding ruling on certain foot rattles. We received two samples from you.


You describe the subject merchandise, item 08498, the Piggie Play Foot Rattle, as tiny rattle/squeaker socks for infants ages birth and up. The merchandise is made of polyester pique knit fabric. You state the merchandise is designed for infants to wear on their feet in a “playing environment”. Each sock has piggy heads with a rattle and squeaker inside of each piggy head. You state the squeaker and rattle helps the infant discover the wonders of playing with his/her tiny toes and listening to the sounds of the rattle and squeaker as the infant moves and kicks his/her feet. You also state the merchandise has a play feature within as the socks are designed to have little piggy heads and numbers so the parent can play “This little piggy” and count the infant’s toes as they play along.


What is the classification of the subject merchandise?


Merchandise is classifiable under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes. When goods cannot be classified solely on the basis of GRI 1 and if the terms of the headings and any relative section or chapter notes do not require otherwise, the remaining GRIs 2 through 6 may be applied.

Additionally, the Harmonized Commodity Description and Coding System Explanatory Notes (ENs) are the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989).

Headquarters Ruling Letters (HQ) 967730 and 967731, both dated December 12, 2005, address CBP’s position on the classification of substantially similar booties with rattles. Accordingly, we incorporate the LAW AND ANALYSIS section of these rulings in this decision. Please find enclosed a copy of the final Notice of Modification, dated January 4, 2006, which contains the two referenced rulings.

Therefore, the merchandise at issue is classified within subheading 6111.30.5050, HTSUSA, which provides for “Babies’ garments and clothing accessories, knitted or crocheted: Of synthetic fibers: OtherOther: Babies’ socks and booties.”


The Piggie Play Foot Rattle, item 08498, is classifiable in subheading 6111.30.5050, HTSUSA, which provides for “Babies’ garments and clothing accessories, knitted or crocheted: Of synthetic fibers: OtherOther: Babies’ socks and booties.” The general column one duty rate is 16 percent. The applicable textile quota category is 239.

Quota/visa requirements are no longer applicable for merchandise which is the product of a World Trade Organization (WTO) member countries. The textile category number above applies to merchandise produced in non-WTO member-countries. Quota and visa requirements are the result of international agreements that are subject to frequent renegotiations and changes. To obtain the most current information on quota and visa requirements applicable to this merchandise, we suggest you check, close to the time of shipment, the “Textile Status Report for Absolute Quotas”, which is available on our web site at www.cbp.gov. For current information regarding possible textile safeguard actions and related issues, we refer you to the web site at the Office of Textiles and Apparel of the Department of Commerce at otexa.ita.doc.gov.


Gail A. Hamill, Chief
Tariff Classification and Marking Branch

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