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NY N022691

February 5, 2008



TARIFF NO.: 6601.10.0000

Andrea Pigott
FedEx Trade Networks
6730 Middlebelt Road
Romulus, MI 48174

RE: The tariff classification of a steel offset umbrella with a base from China

Dear Ms. Pigott:

In your letter dated January 31, 2008, you requested a tariff classification ruling on behalf of your client, Menard, Inc., of Eau Claire, Wisconsin.

The item in question is identified as a10’ steel offset umbrella with a cross base (SKU 2720545/Model #AUQD006S.) The product literature that you have submitted indicates that it is constructed of 60% steel (frame and fasteners), 37% polyester (umbrella), and 3% plastic (rib caps and rib base.) The umbrella is 118” in diameter and 110” tall. You also state that the steel frame is powder coated for protection.

The applicable subheading for the umbrella will be 6601.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for umbrellas and sun umbrellas (including walking stick umbrellas, garden umbrellas, and similar umbrellas): garden or similar umbrellas. The rate of duty will be 6.5% 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 Mitchel Bayer at 646-733-3102.


Robert B. Swierupski

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