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NY N023577

February 29, 2008



TARIFF NO.: 4417.00.8090; 7319.90.9000

Ms. Lisa Pietz
Page & Jones, Inc.
52 N. Jackson Street
P.O. Box 2167
Mobile, AL 36652

RE: The tariff classification of knitting needles from China.

Dear Ms. Pietz:

In your letter dated February 12, 2008, on behalf of The KnittingZone, Inc., Lacey’s Spring, AL, you requested a tariff classification ruling. The samples which you submitted are being returned as requested.

You submitted four packaged samples of knitting needles for review by this office. The first sample is referred to as bamboo circular knitting needles. The knitting needles are made of bamboo and are linked by a plastic cable. Stainless steel attachments connect the plastic cable to the end of each bamboo knitting needle. The retail packaging also includes a stainless steel sewing needle that can be used to attach items such as collars, sleeves or lace to sweater bodies, hats, etc. The second sample consists of five bamboo double point knitting needles packaged for retail sale with a stainless steel sewing needle.

The third sample, referred to as stainless steel circular knitting needles, contains two stainless steel knitting needles that are connected with a plastic cable to achieve a circular pattern with the yarn when knitting. The retail packaging also includes a stainless steel sewing needle. The fourth sample contains five stainless steel double point knitting needles packaged for retail sale with a stainless steel sewing needle.

 The applicable subheading for sample one, the bamboo circular knitting needles with the sewing needle and sample two, the five bamboo knitting needles with the sewing needle, will be 4417.00.8090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tools, tool bodies, tool handles, broom or brush bodies and handles, of wood; boot or shoe lasts and trees, of wood: Other: Other. The rate of duty will be 5.1% ad valorem.

  The applicable subheading for the third sample, the package of stainless steel circular knitting needles with the sewing needle and package four, which contains five stainless steel knitting needles and a sewing needle, will be 7319.90.9000, HTSUS, which provides for sewing needles, knitting needles, bodkins, crochet hooks, embroidery stilettos and similar articles for use in the hand, of iron or steel; safety pins and other pins of iron or steel, not elsewhere specified or included: other: other. The duty rate will be 2.9% ad valorem.

Consideration was given to your proposed classification of 4421.90.9740, HTSUS, for the bamboo knitting needles. Inasmuch, these items are used as a tool when knitting, they are more specifically provided for under heading 4417, HTSUS. In addition, your proposed classification of 7319.90.1000, HTSUS, for the stainless steel knitting needles was deemed incorrect. That subheading only provides for sewing, darning or embroidery needles.

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 Kathy Campanelli at 646-733-3021.


Robert B. Swierupski

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