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NY N007304

March 1, 2007



TARIFF NO.: 5609.00.3000

Steve Franzen
Global Transportation Services
980 Lone Oak Road
Suite 134
Eagan, MN 55121

RE: The tariff classification of a rope tie-down with locking mechanisms from China

Dear Mr Franzen:

In your letter dated February 14, 2006, you requested a tariff classification ruling on behalf of your client, the Miller Bag Company, of Minneapolis, Minn.

The submitted sample is a rope tie-down with locking mechanisms. The rope measures approximately 45” long and 3/8” in diameter and is, as per your telephone conversation with this office, constructed of braided polypropylene. On each end of the rope is a locking mechanism with hard plastic slanted teeth open at the top and narrowing to the bottom. This creates a wedging and locking effect to the rope as it moves in one direction and an unlocking effect when it moves in the opposite direction. The sample will be returned as per your request.

The applicable subheading for the rope tie-down with locking mechanisms will be 5609.00.3000, 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 man-made fibers. The rate of duty will be 4.5% ad valorem.

You suggest that the rope tie-down with locking mechanisms be classified under heading 8479, HTSUS, which provides for mechanical devices. However, the locking mechanism must possess a mechanical feature, such as a ratchet or a pawl mechanism, in order to be classified in heading 8479, HTSUS.

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 Mitchel Bayer at 646-733-3102.


Robert B. Swierupski

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