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NY N003257

November 22, 2006



TARIFF NO.: 5609.00.1000

Joseph R. Hoffacker
Barthco Trade Consultants
The Navy Yard
5101 S. Broad Street
Philadelphia, PA 19112-1404

RE: The tariff classification of a rope belt from India

Dear Mr. Hoffacker:

In your letter dated November 17, 2006, you requested a tariff classification ruling on behalf of your client Urban Outfitters, Inc., of Philadelphia, Pennsylvania.

The submitted sample is identified as a women’s rope belt (Style # bb-121). The belt measures approximately 37”L x 1½”W and is constructed of 80% rope and 20% leather. The four lengths of braided rope are made of 100% cotton. Three leather loops secure the rope and leather fasteners are attached to both ends of the belt. The round belt buckle and the fittings that secure the leather loops are made of metal. It is the cotton ropes that gird the waist and is the sine qua non of the belt.

The applicable subheading for the rope belt will be 5609.00.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles of yarn, twine, cordage, rope, or cables, not elsewhere specified or included: Of cotton. The rate of duty will be 2.9% 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/.

The sample will be returned as requested.

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 Mitchel Bayer at 646-733-3102.


Robert B. Swierupski

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