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NY N018290

October 17, 2007



TARIFF NO.: 5105.29.0000

Heather Gershon
Masterpiece International Ltd.
2300 Higgins Road, Suite 301
Elk Grove, IL 60007-2618

RE: The tariff classification of wool rovings from China

Dear Ms. Gershon:

In your letter dated Oct. 5, 2007, on behalf of Sullivans USA Inc., of Downers Grove, Ill., you requested a tariff classification ruling.

You submitted four small hanks of combed wool fibers in the form of rovings. A roving is an intermediate step in the production of yarn from fibers, beyond sliver but not yet yarns. The fibers have been combed to remove the shorter fibers and to achieve a more parallel alignment of the remaining longer (and hence softer) fibers.

The applicable subheading for the combed wool rovings will be 5105.29.0000, HTSUS, which provides for wool, carded or combed (including combed wool in fragments); wool tops and other combed wool; other. The general rate of duty will be 3.9% ad valorem plus 3.1ยข per kilogram.

However, with regard to the applicable rate of duty, combed wool fibers are also provided for in heading 9902, HTSUS, which covers a wide variety of goods that have a temporary reduction in their rate of duty by virtue of legislative action. The subject items may meet the prerequisites of subheading 9902.51.14, HTSUS, which provides for combed wool having average fiber diameters of 18.5 micron or less (provided for in subheading 5105.29). The rate of duty would be free.

If you would like a ruling on the specific applicability of subheading 9902.51.14, HTSUS, to your product, please supply us with the average wool diameter(s) of the rovings. If you submit such a request, please refer to this letter by its file number, N018290. The samples which you submitted are being retained by this office.

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 Mitchel Bayer at 646-733-3102.


Robert B. Swierupski

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