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NY M84887





July 19, 2006

CLA-2-83:RR:NC:N1:121 M84887

CATEGORY: CLASSIFICATION

TARIFF NO.: 8302.41.6080; 7323.99.9060; 3926.90.9880

Mr. Paul Vroman
Danzas AEI
2660 20th St.
Port Huron, MI 48060

RE: The tariff classification of a rod, a pole, a shelf and a bracket for a closet kit from China

Dear Mr. Vroman:

In your letter dated June 28, 2006, you requested a tariff classification ruling on behalf of your client, Royal Alliance Inc. The merchandise is various components of the Extend-it Custom Closet Kit.

The Vertical Pole is designed to support the other components of the closet kit, which include the shelves, rods, etc. Each pole is made of three powder coated steel bars and plastic components. It attaches to an existing clothes rod via a spring clip on the upper portion of the pole. The bottom portion has a plastic foot that sits on the floor. The pole is secured in place via a telescoping feature with a compression fitting.

The Horizontal Rod attaches to the vertical poles of the closet kit. It provides rigidity to the unit and a device to hang clothes. Each rod is composed of two powder coated steel bars and plastic brackets, which attach to the vertical poles. The vertical pole is inserted through a hole in the bracket. The rod is adjusted by sliding the brackets on the pole, then tightened to the pole via a compression fitting. The rod is telescopic and adjustable in length.

The Expandable Shelf is a shelf made of powder coated steel bars and plastic components. It is designed to attach to the vertical poles via brackets.

The Shelf Bracket is a bracket made of ABS plastic. It attaches to the shelf via plastic thumbscrews and is designed to attach the shelf to the vertical poles. The vertical pole is inserted through a hole in the bracket. The shelf is adjusted by sliding the brackets on the pole, then tightened to the pole via a compression fitting.

The applicable subheading for the vertical pole and the horizontal rod will be 8302.41.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articlesother mountings, fittings and similar articles, and parts thereof, suitable for buildings, other, of iron or steel, of aluminum or of zinc, other. The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for the expandable shelf will be 7323.99.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for table, kitchen or other household articles and parts thereof, of iron or steelother, other, not coated or plated with precious metal, other, other, other. The rate of duty will be 3.4 percent ad valorem.

The applicable subheading for the shelf bracket will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics and articles of other materials of headings 3901 to 3914, other, other, other. The rate of duty will be 5.3 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Barbara Kaiser at 646-733-3024.

Sincerely,

Robert B. Swierupski
Director,

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