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NY N024286

March 20, 2008



TARIFF NO.: 9506.91.0030

Ms. Kerry L. Welsh
WelCom Products Inc.
800 S. Pacific Coast Highway
Redondo Beach, CA 90277

RE: The tariff classification of the “Spinal Stretch” from China

Dear Ms. Welsh:

In your letter dated March 5, 2008, you requested a tariff classification ruling.

The product that has been presented for a tariff classification determination is identified as a back-stretching device that is called the “Spinal Stretch”. It is a portable exercise device that is comprised of nylon straps, a waistband with a hook and loop closure, an adjustable pole, a small metal ratchet, and other small metal parts of the device. The “Spinal Stretch” is marketed as an effective pain-relieving tool for lower back discomfort and not as a substitute for medical treatment.

The applicable subheading for the “Spinal Stretch” will be 9506.91.0030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Articles and equipment for general physical exercise, gymnastics, athletics, other sportsparts and accessories thereof: Other: Articles and equipment for general physical exercise, gymnastics or athletics; parts and accessories thereofOther.” The rate of duty will be 4.6% 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 James Forkan at 646-733-3025.


Robert B. Swierupski

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