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NY N016673

September 28, 2007



TARIFF NO.: 3917.32.0020

Ms. Sandra Welsh
Orbit Irrigation Products, Inc.
845 North Overland Road
North Salt Lake, UT 84054

RE: The tariff classification of polyethylene tubes from China

Dear Ms. Welsh:

In your letter dated August 24, 2007, you requested a tariff classification ruling. The samples that you submitted are being returned.

Four samples were included with your request. Styles 37128 and 37126 are identified as multi-flex risers. Styles 37169 and 37017 are identified as cut-off risers. All are lengths of non-reinforced polyethylene plastic tubing intended for use with sprinkler systems. They are threaded to facilitate connections to other tubes and other components. They do not incorporate any valve mechanisms to control the flow of water to the sprinkler heads, nor do they incorporate any mechanical components or moving parts.

The applicable subheading for the tubes will be 3917.32.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tubes, pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: other, not reinforced or otherwise combined with other materials, without fittingsof polyethylene. The rate of duty will be 3.1 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 Joan Mazzola at 646-733-3023.


Robert B. Swierupski

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