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NY N012127

June 18, 2007



TARIFF NO.: 9507.30.4000

Mr. William F. Reagan III
Hellman Worldwide Logistics
1200 Minters Chapel Road
Suite 300
Grapevine, Texas 76051

RE: The tariff classification of a Fishing Combination Set from China

Dear Mr. Reagan:

In your letter dated June 4, 2007, you requested a tariff classification ruling, on behalf of W.C. Bradley/Zebco Holdings Inc., your client.

You are requesting the tariff classification on a product that is identified as a Fishing Combination Set; no item number has been designated for the set. The following three components make up the set: 1 two-piece medium weight fishing rod, 1 Model 33 medium-light weight closed face fishing reel pre-loaded with fishing line, and 1 Model 22 light-weight closed face fishing reel also pre-loaded with fishing line. Model 33 is valued at $3.26 each and Model 22 is valued at $3.18 each.

The product is sold and marketed as a set and it will also be considered a set for the purposes of the tariff. No one heading in the tariff schedule covers these components in combination; GRI 1 cannot be used as a basis of classification. GRI 3 provides for goods that are, prima facie, classifiable in two or more headings. GRI 3 (b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. GRI 3 (c) provides that when goods cannot be classified by reference to GRI 3 (b), they are classified in the heading/subheading of the tariff that occurs last in numerical order among those that equally merit consideration.

Noting GRI-3 (c), the heading/subheading that occurs last in numerical order among those that merit equal consideration will determine the classification of the set. The heading/subheading for the fishing reels occurs last in numerical order in the HTSUS among those that equally merit consideration. Therefore, the applicable subheading for the Fishing Combination Set will be 9507.30.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for fishing reels and parts and accessories thereof: fishing reels: valued over $2.70 but not over $8.45 each. The rate of duty will be 24ยข each.

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 Tom McKenna at 646-733-3025.


Robert B. Swierupski

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