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NY N003261

December 13, 2006



TARIFF NO.: 4421.90.9740

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

RE: The tariff classification of fabric covered wood letters from India

Dear Mr. Hoffacker:

In your letter dated November 2, 2006, on behalf of the importer, Urban Outfitters Inc., you requested a tariff classification ruling.

The ruling was requested on fabric covered wood letters, product # SPR07, Style # 06/06/06/06/ A-Z. A sample of one letter was submitted, which will be returned to you as you requested. (The sample was cut as part of our examination.) The sample is a letter “C” measuring approximately 9” long x 8” wide x 1-1/4” thick. It is composed of medium density fiberboard (MDF) and decoratively covered with a printed fabric. A ¼” thick layer of foam is inserted between the fabric and the wood on the face of the letter only. Two metal hangers are attached to the back, enabling the letter to be hung on a wall.

The product is a composite good, composed primarily of MDF wood and fabric. The essential character is imparted by the wood because of the greater role the wood plays in the making and functioning of the article.

The applicable subheading for the fabric covered wood letters, product # SPR07, Style # 06/06/06/06/ A-Z, will be 4421.90.9740, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of wood. The duty rate will be 3.3 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/.

Articles classifiable under subheading 4421.90.9740, HTSUS, which are products of India may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term "GSP".

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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