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NY N021209

January 9, 2008

CLA-2-05: RR: NC: SP: 231


TARIFF NO.: 0511.99.2000

Ms. Maureen Ford
One Geoffrey Way
Wayne, NJ 07470-2030

RE: The tariff classification of a rawhide dog chew from China.

Dear Ms. Ford:

In your letter dated December 20, 2007, you requested a tariff classification ruling.

The submitted sample, item no. 196711 is described as a “Rawhide Greeting Card for a Dog” which is an edible dog treat in the shape of a traditional greeting card. The item consists of two tan colored rawhide sheets that are approximately 5” (W) x 6 ½” (L) and are trussed together on the left side of the card with a small rawhide strip. The face / front sheet is decorated with a white colored rawhide backing sheet and a maroon colored rawhide facsimile of a dog’s head which are attached to the sheet with two rawhide strips in such a way as to mimic the eyes and nose of a dog.

The applicable subheading for item no. 196711 “Rawhide Greeting Card for a Dog” will be 0511.99.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for animal products not elsewhere specified or included; dead animals of chapter 1 or 3, unfit for human consumption, other, other, parings and similar waste of raw hides or skins; glue stock not elsewhere specified or included. The rate of duty will be Free.

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/.

We note that the submitted sample is not marked with the country of origin. Therefore, if imported as is, the dog chew will not meet the country of origin marking requirement of 19 U.S.C. 1304. Accordingly, the dog chew will be considered not legally marked under the provisions of 19 C.F.R. 134.11 which states, “every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit.”

We are returning the sample as you requested.

Questions concerning possible FDA or USDA requirements should be addressed to those agencies at the following locations:

U.S. Food and Drug Administration (FDA)
5600 Fishers Lane
Rockville, MD 20857
Telephone: (301) 443-6553

U.S. Department of Agriculture (USDA)
Products Program
4700 River Road, Unit 40
Riverdale, MD 20737-1231
Telephone: (301) 734-3277

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 Nathan Rosenstein at 646-733-3030.


Robert B. Swierupski

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