CLA-2-84:S:N:N1:103 885105

Ms. Shirley M. Stroupe
Accent Customs Service
Peace Bridge Plaza Warehouse
P.O. Box 221
Buffalo, NY 14213

RE: The tariff classification of the Dinghy-Tow from Canada

Dear Ms. Stroupe:

In your letter dated April 5, 1993 on behalf of Davron Marine Products Inc. of Richmond Hill, Ontario, Canada you requested a tariff classification ruling.

The Dinghy-Tow is utilized on sailboats for lifting and storing an inflatable dinghy. It contains two stainless steel poles, attached to brackets on the stern rail of the sailboat, which connect to brackets mounted on the transom of the dinghy using snap-on, quick-release fasteners. The Dinghy-Tow's pulley tackle, attached to the stern rail and to the outer ends of the poles, allows an individual in the boat cockpit to easily lift the stern of the dinghy out of the water. The dinghy can then be towed backwards with only its bow in the water, resulting in less drag on the sailboat while also supporting the dinghy at its strongest point. To store a dinghy which is in the towing position the dinghy's bow line is pulled in, pivoting the dinghy about the outer ends of the poles. This causes the dinghy to come completely out of the water and allows it to be securely stored in a vertical position on the sailboat's stern. While the dinghy is stored in this position its outboard motor is readily accessible for manual removal.

The applicable subheading for the Dinghy-Tow will be 8425.19.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other pulley tackle and hoists. The duty rate will be 2 percent ad valorem.

Goods classifiable under subheading 8425.19.0000, HTS, which have originated in the territory of Canada, will be entitled to a free rate of duty under the United States-Canada Free Trade Agreement (FTA) upon compliance with all applicable regulations.

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 transaction.

Sincerely,

Jean F.
Maguire
Area
Director
New York
Seaport