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NY N014501




August 16, 2007

CLA-2-39:RR:NC:N2:222

CATEGORY: CLASSIFICATION

TARIFF NO.: 3924.90.5600

Ms. Francine Ramsey
Hampton Direct Inc.
P.O. Box 1199
Williston, VT 05495

RE: The tariff classification of a plastic and iron doorstopper from China

Dear Ms. Ramsey:

In your letter dated July 13, 2007 you requested a tariff classification ruling.

The submitted sample is identified as Set/2 Doorstoppers, SKU# 62400. Two individual and identical doorstoppers are packaged together for retail sale under this SKU#. Each doorstopper is comprised of a thin, flexible, rectangular iron strip, which measures 4-1/4 inches long by 1-3/8 inches wide. There are two round grippers that are attached to the underside of the iron strip, one on each end, so that the iron strip balances on them.

Each gripper has a series of ten ridges along its round external surface area and each gripper is attached to the iron strip by two Philips head screws. The grippers are made of PVC and are situated 3 inches apart from each other. The plastic grippers overlap the edge of the iron strip on both ends so that the total measurement of the doorstopper is 5 inches long by 1-3/8 inches wide and stands 1-1/2 inches high.

The iron strip is flexible enough and thin enough to be manually bent and slipped under a door. Once the doorstopper is in place, the grippers prevent the door from being moved by drafts.

This item is considered to be a composite good within the meaning of General Rule of Interpretation (GRI) 3. The PVC grippers provide the item with the traction resistance needed, when in contact with the floor, to prevent the door from easily being moved. The iron strip provides the subsidiary function of connecting the two grippers, so that the grippers sit one on each side of the door when the iron strip is slipped under the door. Therefore, it is the opinion of this office that the PVC grippers provide this item with the essential character within the meaning of GRI 3(b).

The applicable subheading for SKU# 62400 will be 3924.90.5600, Harmonized Tariff Schedule of the United States (HTSUS), which provides forother household articlesof plastic: other: other. The rate of duty will be 3.4 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.

Sincerely,

Robert B. Swierupski
Director,

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