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NY N006837

March 15, 2007



TARIFF NO.: 4823.90.8600; 6307.90.9889

Ms. Alyssa S. Aron
International Diversified Products
13409 Saticoy St.
North Hollywood, CA 91605

RE: The tariff classification of polyurethane covered paperboard holders from China

Dear Ms. Aron:

In your letter dated February 1, 2007, which was received in our office on February 13, 2007, you requested a tariff classification ruling.

The ruling was requested on two products stated to be made of chipboard and covered with polyurethane. The products are referred to as a “Polyurethane Panel” and a “Hotel Closet Organizer.” Samples of the products were submitted.

The “Polyurethane Panel” is a flat rectangular mat with corner pockets. It is composed of paperboard and covered on one side with a sheet of polyurethane plastic, which is glued thereon. The sample measures approximately 5-1/2” x 8-3/4”; however, other panel sizes to be imported are 8-1/2” x 11”, 8-1/2” x 14”, 4-1/4” x 11” and 5-1/2” x 11”. The panels will be used as holders for advertising, memos or other printed media that are placed in hotel guest rooms and public areas.

The subject “Polyurethane Panel” is a composite good composed equally of paperboard and polyurethane plastic. Both materials are visible and both play a significant role in the functioning of the product. General Rule of Interpretation 3 (c) of the Harmonized Tariff Schedule states that composite goods which cannot be classified according to one material that imparts the essential character, shall be classified according to the material that appears last in the tariff schedule. Paperboard (chapter 48) appears after plastic (chapter 39).

The applicable subheading for the “Polyurethane Panel” described above will be 4823.90.8600, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other (non-enumerated) articles of paper or paperboard. The rate of duty will be free.

The “Hotel Closet Organizer” is a rectangular flat panel with three horizontal gusseted pockets, measuring overall 10-1/2” x 11-1/2”. It is constructed (sewn) of woven textile fabric covered with non-cellular plastic sheeting. Paperboard stiffeners are placed inside the flat back panel and in the front panels of the pockets. The paperboard is not visible and plays a secondary role in the functioning of this product. The essential character of this product is imparted by the textile material. The “Hotel Closet Organizer” will be used to hold laundry/dry cleaning orders, small laundry bags and similar items and placed in hotel room closets.

The applicable subheading for the “Hotel Closet Organizer” described above will be 6307.90.9889, HTSUS, which provides for other made up textile articles, other. The rate of duty will be 7 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 Carl Abramowitz at 646-733-3037.


Robert B. Swierupski

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