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NY R03887

June 2, 2006

CLA-2-44:RR:NC:2:230 R03887


TARIFF NO.: 4419.00.8000; 4420.90.4500; 4420.90.8000

Mr. Joseph B. Lynch
One Degree North
10 Anson Rd #10-29
International Plaza
Singapore 079903
Republic of Singapore

RE: The tariff classification of lacquered wood vases, napkin rings, boxes and wine bottle holders from Vietnam

Dear Mr. Lynch:

In your letter dated May 5, 2006 you requested a tariff classification ruling.

The ruling was requested on various decorative household products. Photographs and a description of the decorative finishing process were submitted.

The products consist of vases, plates, bowls, napkin rings, trays, boxes and wine bottle holders. The wine bottle holders consist of crescent shaped stands with holes designed for the necks of wine bottles. The products are manufactured from various materials, such as wood (mango wood), bamboo, plastic, ceramics and medium density fiberboard (MDF). A highly polished decorative finish is applied to the products in fourteen steps. Twelve of the steps involve the application of layers of lacquer resin with various additional materials such as paint and wood powder, alluvial soil and stone powder, cotton gauze and wood powder, treated eggshell (chicken, duck, snake) and oil. The surface is frequently polished. The final step is a coating of polyurethane.

The applicable subheading for the napkin rings made of mango wood or of MDF will be 4419.00.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tableware and kitchenware of wood, other. The duty rate will be 3.2 percent ad valorem.

The applicable subheading for the boxes made of mango wood or of MDF will be 4420.90.4500, HTSUS, which provides for jewelry boxes, silverware chests, cigar and cigarette boxes, microscope cases, tool or utensil cases and similar boxes, cases and chests, all the foregoing of wood, other, not lined with textile fabrics. The duty rate will be 4.3 percent ad valorem.

The applicable subheading for the vases and the wine bottle holders made of mango wood or MDF will be 4420.90.8000, HTSUS, which provides for wooden articles of furniture not falling within chapter 94. The duty rate will be 3.2 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/.

Importation of these products may be subject to import regulations administered by the U.S. Department of Agriculture (U.S.D.A.). Information regarding applicable regulations administered by the U.S.D.A. may be addressed to that agency at the following location:

U.S. Department of Agriculture
4700 River Road, Unit 136
Riverdale, MD 20737

Your inquiry does not provide enough information for us to give a classification ruling on the bowls, plates and trays made of mango wood or MDF. Your request for a classification ruling for these products should include a description of how these are used (i.e, are they used to serve food, or will they be labeled “not for food use”). When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request for these products, please include a copy of this letter.

Requests for rulings must be limited to a maximum of five products of the same class or kind. In this letter, we have not considered the products made of the other materials, namely, bamboo, plastic and ceramic. You should submit separate ruling requests for each of these classes of products and include no more than five specific products in each request. In addition, when submitting a request for the bamboo products, please describe the type of bamboo (e.g., interwoven strips of bamboo) the products are made of. When submitting a request for the ceramic products, please describe the type of ceramic (e.g., dolomite, earthenware, bone china, porcelain, etc.) the products are made of. State whether the products are for food use.

The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in 19 CFR 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, either directly, by reference, or by implication, is accurate and complete in every material respect.

This ruling is being issued under the assumption that the subject goods, in their condition as imported into the United States, conform to the facts and the description as set forth both in the ruling request and in this ruling. In the event that the facts or merchandise are modified in any way, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and you should resubmit for a new ruling in accordance with 19 CFR 177.2. You should also be aware that the material facts described in the foregoing ruling may be subject to periodic verification by the CBP.

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 Paul Garretto at 646-733-3035.


Robert B. Swierupski

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