CLA-2-87:RR:NC:1:101 A87718

Ms. Sandra L. Haupt
Tower Group International, Inc.
128 Dearborn Street
Buffalo, NY 14207-3198

RE: The tariff classification of automotive accessories from China

Dear Ms. Haupt:

In your letter dated September 5, 1996 you requested a tariff classification ruling on behalf of Autoshade L.L.C. of Moorpark, California.

The first item concerned (pictured below) is the Trunk Lid Organizer (Item #141306); it is a rectangular textile article of black nylon with PVC backing. Six cords, one attached to each corner and one each to the top-center and bottom-center, with hooks on the unattached ends, are used to attach the Organizer to the inside lid of a vehicle trunk. The Organizer, itself, measures 25" in length and 10«" in height. There are two zippered pockets sewn to the outside of the Organizer: one measuring 13«"L X 9«"H and the other measuring 8«"L X 9«"H.

You state that the function of the Trunk Lid Organizer is to expand the storage space of a vehicle trunk; in particular, for highway emergency articles. The second item (pictured below) is the Backseat Travel Tray (Item #142402). It is a rectangular, briefcase-sized, folding article composed of two sewn-in cardboard squares covered with black nylon. There is one, 9"H X 12«"L, mesh pocket sewn onto the bottom outside of the "tray" portion of the article and four nylon strips with sewn-in Velcro closures sewn onto the top outside portion which are used to "belt" the Travel Tray to the back of a vehicle seat. A cord passes through two holes in both the "tray" and top portions of the article and passes through a hard, plastic cordlock which provides adjustable tension to allow the "tray" to remain stable at a desirable angle. There are four pockets sewn into the inside of the top portion of the article; three with Velcro closures and one intended as a cup holder. Sewn into the outside of the upper inner pocket is an open-ended rectangular piece of nylon which is intended as a sunglasses' holder. There is a zipper sewn around the outside edge of the items center, when folded; a nylon, strip handle sewn into the center of the exterior flap of the items top portion and, alongside, a nylon strip which can attach to a sewn-on Velcro square at the top of the outside of the "tray" portion of the item thereby keeping the item "closed". The item measures 11«"H X 15"W X 3«"Depth.

[Closed] [Open]

You state that the purpose of this item is to allow passengers in the rear seats of vehicles to store things and have a surface to eat, write or play games on, etc.

The third item (shown below) is the Backpack Backseat Organizer (Item #14510). It is an oblong-shaped article of black nylon with an open-topped pocket and a mesh pocket sewn onto the front outside surface along with a -length zipper around the top portion; on the top of the back outside surface is a sewn-in belt with a hard plastic buckle and clasp and on the bottom of the back outside surface are two sewn-in nylon loops and two short pieces of belt webbing with hard plastic D-rings attached. On the front inside of the item is a sewn-in, multi-looped piece of elastic. On the back inside, are two Velcro-closured pockets. A loose piece of nylon drawcord is included to fit through either the loops or D-rings on the bottom of the back outside surface of the item to tie it down to various lengths of vehicle seats. The item measures 3"L X 11"W X 17«"H.

[Closed] [Open]

You state that the function of this item is to hold or store items in an organized fashion within an automobile.

The last item (shown below) is the Glove Box Litter Bag (Item #14521). It is a 11"H X 8«"W X 3"Depth, rectangular, black nylon bag with PVC backing. There is a top flap which has a sewn-on Velcro closure on the front. On the back are two webbed loops. Included are two, soft metal, bendable hooks covered with black rubber material; they "hook" through the webbed loops on the back of the Bag and the other end of the hooks are "hooked" to the Glove Compartment or Glove Box of a vehicle.

You state that the purpose of this item is to hold litter.

All of the items listed above are supplied by A.S. Sheng Chan International and will be imported into the U.S. through the Ports of Los Angeles and Long Beach, California.

The applicable subheading for the Trunk Lid Organizer, Backseat Travel Tray, Backpack Backseat Organizer and Glove Box Litter Bag will be 8708.99.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories for . . . motor vehicles . . . : Other parts and accessories: Other: Other: Other: Other: Other. The rate of duty will be 2.9% ad valorem.

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 Robert DeSoucey at 212-466-5667.


Roger J. Silvestri
National Commodity
Specialist Division