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NY N007747

March 20, 2007



TARIFF NO.: 0505.10.00

Mr. Casimir J. Ries
Rotra Brokerage Services
P.O. Box 66498
Chicago, IL 60191

RE: The tariff classification of Lyocelldown from China

Dear Mr. Ries:

In your letter dated February 26, 2007, on behalf of your client, United Feather and Down Inc., you requested a tariff classification ruling.

The sample submitted is item number Lyocelldown F5502-FAB. Lyocelldown is composed of 70% white duck down (75% down cluster) and 30 % lyocell fiber. The cleanliness ranges from 800 milliliter (3.6 NTU) to 1000 milliliter (2.7 NTU) and the oxygen is under 3.2. The fill power ranges from 460 cubic square inches per ounce to 540 cubic square inches per ounce. The value of Lycocell material is $2.98 per pound and the value of the white duck down material is $12.75 per pound. The white duck down by weight is valued at 80% of the total cost.

The applicable subheading for Lyocelldown will be 0505.10.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for skins and other parts of birds, with their feathers or down feathers and parts of feathers (whether or not with trimmed edges) and down, not further worked than cleaned, disinfected or treated for preservation; powder and waste of feathers or parts of feather: feathers of a kind used for stuffing; down. The rate of duty will be Free.

At this time, we are unable to provide you with a tariff classification number to the statistical (10 – digit) level for this merchandise. Federal Standard 148a was cancelled as of September 13, 2006. This standard has been replaced by the American Society for Testing and Materials D 4522, Standard Specification for Feather and Down Fillings for Textile Products, which references the International Down and Feather Bureau Test Regulations. Presently, the HTSUS has not been modified to reflect this change.

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 the 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 Rosemarie Hayward at 646-733-3064.


Robert B. Swierupski

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