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NY N007066

March 6, 2007



TARIFF NO.: 5609.00.3000

Victoria James
Mallory Alexander International Logistics LLC P.O. Box 30209
4294 Swinnea Road
Memphis, TN 38118

RE: The tariff classification of water sport accessories from China

Dear Ms. James:

In your letter dated Jan. 24, 2007, received in our office on Feb. 20, you requested a tariff classification ruling on behalf of your client, Floateyes LLC.

You submitted four items. The first is called β€œThe Wetcord – Personal Watercraft Lanyard, Life-Vest Style.” It is used as an engine stop switch for personal watercraft. It is composed of a band (made of 1/2"-diameter foam covered with knit textile fabric) that attaches to a coiled 1/8” cord (made of man-made textile fibers covered in a plastic sheath). At one end of the cord is a plastic lock-plate, which you state is the device that stops the engine if the operator falls off and breaks the connection to the ignition. Each lock-plate is made to fit a specific brand of watercraft. At the other end is a plastic clip that attaches to a life vest.

The above item is a composite good as defined by General Rule of Interpretation (GRI) 3, Harmonized Tariff Schedule of the United States (HTSUS). Neither the foam cord nor the plastic-covered textile cord nor the plastic parts impart the essential character to this item. When the essential character of the overall product cannot clearly be ascribed to a single material, GRI 3(c) directs that the classification will be the heading that appears last in numerical order among those that equally merit consideration. The competing headings here are in chapter 39 (foam, plastic parts) and chapter 56 (plastic-sheathed man-made fiber cord). Chapter 56 appears last in the tariff among these.

The applicable subheading for the Wetcord will be 5609.00.3000, HTSUS, which provides for articles of cordage not elsewhere specified, of man-made fibers. The rate of duty will be 3.9% 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/.

Your inquiry does not provide enough information for us to give a classification ruling on Stingerz, Floateyes, or Vision Buoys. Your request for a classification ruling must include a cost breakdown for each component (foam, including its name; plastic; textile). When this information is available, you may wish to consider resubmission of your request. We are returning all the samples. If you decide to resubmit your request, please include all of the material that we have returned to you.

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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