Mr. Thomas Knauff
Knauff & Grove, Inc.
RR # 1, Box 414
Julian, PA 16844
RE: The tariff classification of a Cobra trailer from Germany
Dear Mr. Knauff:
In your letter dated November 25, 1992 you requested a
tariff classification ruling. You have submitted literature
describing the Cobra trailer.
The imported product is an enclosed wheeled trailer that is
designed specifically for the storage and transporting of a
glider (sailplane). The glider is placed indide the trailer, and
the hinged top portion is then closed. Inside the trailer the
glider is protected against damage. The literature states that
the trailer has a low profile, a low center of gravity and an
aerodynamic design to facilitate perfect road handling. The
trailer can remain connected to the tow vehicle while rigging or
derigging the plane.
The galvanized chassis is equipped with an extra soft rubber
suspension, an axle with two wheels located at the approximate
midpoint of the trailer, an overrunning brake, a parking brake, a
reverse gear, an extra large support wheel in front, and high
quality tires. The bottom portion of the chassis is made of
aluminum, the top portion is made of either aluminum or
fiberglass. Other features of the trailer include a large
opening angle, tip-proof wing dollies, and an automatic locking
of all sailplane parts. The Cobra trailer is attached to the
towing vehicle by means of a draw/tow bar.
The Explanatory Notes to the Harmonized Tariff Schedule,
which constitutes the official interpretation of the tariff at
the international level, states that "this heading (87.16) covers
a group of non-mechanically propelled vehicles equipped with one
or more wheels and constructed for the transport of goods or
persons.... The vehicles of this heading are designed to be
towed by other vehicles (tractors, trucks, etc.)...." The Cobra
trailer for the glider (sailplane) meets this definition.
The applicable subheading for the Cobra trailer will be
8716.39.0090, Harmonized Tariff Schedule of the United States
(HTS), which provides for other trailers and semi-trailers for
the transport of goods, other. The rate of duty will be 3.1
percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport