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NY N011495

June 11, 2007



TARIFF NO. 3924. 90.5600; 3926.90.6550

Ms. Tonya Simpson
International Brokerage Services, Inc.
P.O. Box 20887
Atlanta, GA 30320

RE: The tariff classification of a plastic Bra Baby, a plastic clothespin and plastic hangers from China.

Dear Ms. Simpson:

In your letter dated May 1, 2007, on behalf of your client The Evercare Company, you requested a tariff classification ruling.

You have submitted samples of items identified as a Bra Baby, a Tide Clothespin, a Tide Smart-Dry Hanger and a Tide Smart Design Deluxe Hanger. All samples are made of plastic. As you requested, the samples will be returned to you.

The Bra Baby is composed of an oval inner plastic shell and an oval outer plastic shell, each of which is designed with numerous ventilation holes of various sizes and shapes. The Bra Baby is designed to prevent damage to a padded bra when placed in a washing machine. The outer shell of the Bra Baby is opened by turning a small plastic slab that has two small legs that extend through two small apertures located on one side of the outer shell. When the slab is turned, the legs can be pulled through one of the apertures and the two halves of the outer shell can be separated on one side, while plastic hinges keep the two halves together on the other side. The Bra Baby is used by placing each cup of a bra around opposing ends of the inner shell and tucking the straps inside the inner shell through one of the ventilation holes. The inner shell is then placed inside the opened outer shell and the outer shell is then closed and locked around the inner shell. The Bra Baby is then placed in the washing machine. After washing, the Bra Baby can be placed in the dryer. The Bra Baby eliminates piling, snags and rips, thereby preserving delicate lace and cotton. It also maintains flat bra straps, prevents bent or broken hooks, works with every wash cycle and fits cup sizes AA, A, B, C and D. The Bra Baby is not recommended for use with the padded D cup size bras.

The Tide Clothespin consists of two round pieces of molded plastic, each approximately 1-3/4 inches in diameter, that are held together with a thin plastic strip that is located in between the two round pieces. A metal spring is also located in between the upper half of the two pieces. The word “Tide” is molded on the outside of each piece. One of the plastic pieces has a lip with an indentation at the end which is designed for the user’s thumb. The other plastic piece has a lip with a hook designed for hanging on a clothesline. When the user presses the two lips together, the other end of the two plastic pieces move farther apart, thereby allowing the article of clothing to be inserted. When the user lets go of the lips, the spring extends and forces the other side of the two plastic pieces to snap back together around the article of clothing. The portion of the clothespin that will hold the clothing has a plastic grip surface to prevent slippage.

The Tide Smart-Dryer Hanger is made of plastic with slots for ventilation for drying clothing. It is fashioned with a swivel hook at the top. The bottom of the swivel plastic hook has a small plastic support that has the word “Tide” molded onto one side.

The Tide Smart Design Deluxe Hanger is made of plastic with a swivel hook at the top. This hanger has a semi hook on either side to aid in hanging clothes with straps. The bottom of the swivel hook has a plastic support that has the word “Tide” molded onto one side. A strip of plastic grip material is on either side and across the bottom of the hanger to prevent slippage of the garments.

The applicable subheading for the plastic Bra Baby and the two hangers will be 3924.90.5600, Harmonized Tariff Schedule of the United States (HTSUS), which provides forother household articlesof plastics: other: other. The rate of duty will be 3.4 percent ad valorem.

  The applicable subheading for the clothespin will be 3926.90.6550, HTSUS, which provides for other articles of plastics and articles of other materials of heading 3901 to 3914: other: clothespins: spring type, valued over $1.70 per gross. The rate of duty will be 4.2 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 Gary Kalus at 646-733-3055.


Robert B. Swierupski

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