CLA-2 CO:R:C:G  084134 DSN
Mr. E. Thomas Watson
          Parker, Poe, Thompson, Bernstein, Gage & Preston
          2600 Charlotte Plaza
          Charlotte, North Carolina 28244
          RE:  Classification of sectional unit
          Dear Mr. Thomas:
                This ruling letter is in response to your request of March
          20, 1989, on behalf of Natuzzi Upholstery, Inc., for
          classification under the Harmonized Tariff Schedule of the United
          States Annotated (HTSUSA), for a sectional unit produced in
          Italy.  Pictures and a bolt were submitted for examination.
          FACTS:
                The merchandise at issue is a five piece sectional unit.
          It is described by codes for easier identification.  The pieces
          are designed to form a sectional sofa.  Code 01 identifies an
          armless chair.  Code 47 identifies the left arm facing the chair.
          Code 49 identifies the right arm facing the chair.  Code 00
          identifies the chair with one left arm and code 02 identifies the
          chair with one right arm.
                The frames of each section are wood upholstered with
          leather.  The sides of the individual sectional pieces are not
          upholstered in leather but in fabric which is to be used only as
          part of the sectional.  Each section has a connector plate-bolt
          which links the pieces together.
                You assert that the sections are imported with the sofa and
          cannot be sold as individual units, and therefore, should be
          classified together.  
-2-
          ISSUE:
                What is the classification of a sectional unit under the
          HTSUSA?
          LAW AND ANALYSIS:
                Classification of merchandise under the HTSUSA is in
          accordance with the General Rules of Interpretation (GRI's),
          taken in order.  GRI 2(a) provides for articles that are
          incomplete or unassembled.  GRI 2(a) states that any reference in
          a heading to an article includes articles that are incomplete or
          unfinished, provided that the article has the essential character
          of a complete or finished article.  The sections at issue,
          though incomplete without being connected, are nevertheless
          dedicated to a sectional sofa.  The articles do not have any
          commercial reality apart from being connected into an assembled
          sofa and are not sold separately.  Furthermore, all the sections
          needed to make up a complete sofa sectional are imported together
          and each section contains a connector plate-bolt for easy
          assembly.  Thus the sectional at issue is classified together.
                Heading 9401, HTSUSA, provides for seats (other than those
          of heading 9402), whether or not convertible into beds, and parts
          thereof.  The Explanatory Notes constitute the official
          interpretation of the tariff at the international level.  The
          Explanatory Notes for heading 9401, state that the heading covers
          all seates such as benches, couches, settees, sofas, ottomans and
          the like.  Since the merchandise at issue is upon assembly a
          sofa, it is classifiable under this heading.
          HEADING:
                The merchandise at issue is classified under subheading
          9401.61.6000, HTSUSA, which provides for seats (other than those
          of heading 9402), whether or not convertible into beds, and parts
          thereof, other seats, with wooden frames, upholstered, other, and
          dutiable at the rate of 2.5 percent ad valorem.
                                        Sincerely,
John Durant, Director
                                        Commercial Rulings Division