OT:RR:CTF:CPMM:MAB
Ms. Paula Dunn
Nexus Rubicon 57
Maxwill Ave.
Toronto, Ontario
Canada M5P2B4
RE: Revocation of NY 891581; classification of a reflective cat collar
Dear Ms. Dunn,
This is in reference to the New York Ruling Letters (NY) 891581 issued to you by U.S.
Customs and Border Protection (CBP) on November 1, 1993, concerning the classification of a
reflective cat collar under the Harmonized Tariff Schedule of the United States (HTSUS). We
have reviewed this ruling, and determined it is incorrect, with respect to the classification of the
reflective cat collar under subheading 4201.00.3000, HTSUS, the provision for “saddlery and
harness for any animal (including traces, leads, knee pads, muzzles, saddle cloths, saddlebags,
dog coats and the like), of any material: Dog leashes, collars, muzzles, harnesses and similar dog
equipment.” For the reasons set forth below, we are revoking the ruling.
Pursuant to Section 6125(c), Tariff Act of 1930 (19 U.S.C. 1625(c)), as amended by
Section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement
Implementation Act (Pub. L. 103-182, 107 Stat. 2057), this notice advises interested parties that
CBP is revoking the above noted ruling concerning the classification of a cat collar under the
HTSUS. Similarly, CBP is revoking any treatment previously accorded by it to substantially
identical transactions. Notice of the proposed revocation was published on July 7, 2021, in
Volume 55, Number 26, of the Customs Bulletin. One comment in agreement was received in
response to the proposed notice.
FACTS:
The merchandise under consideration is identified as a cat collar. The "tenth life" collar is
a reflective, adjustable, break away cat collar. The item consists of nylon webbing or elastic with
a reflective film on top. It has a plastic buckle and glide and a steel rectangular D-ring. The collar
is used for cat identification and as a safety device to increase a cat’s visibility at night to
automobiles.
ISSUE:
Whether the subject merchandise consisting of a reflective cat collar should remain
classified in subheading 4201.00.3000, HTSUS, as “saddlery and harness for any animal...
Dog leashes, collars…” or subheading 4201.00.6000, HTSUS, as “other [harness for any
animal].”
LAW AND ANALYSIS:
Classification of goods under the HTSUS is governed by the General Rules of
Interpretation (GRI). GRI 1 provides that classification shall be determined according to
the terms of the headings of the tariff schedule and any relative section or chapter notes. In
the event that the goods cannot be classified solely on the basis of GRI 1, and if the
headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may
then be applied in order.
The HTSUS provisions at issue are as follows:
*****
4201.00 Saddlery and harness for any animal (including traces, leads, knee pads, muzzles, saddle
cloths, saddle bags, dog coats and the like), of any material:
4201.00.3000 Dog leashes, collars, muzzles, harnesses and similar dog equipment
4201.00.6000 Other
*****
As noted above, the merchandise was originally classified in subheading 4201.00.3000, HTSUS
which comprises of dog leases, collars and other similar dog equipment. The present
merchandise, however, is a cat collar, and therefore is not provided for in subheading
4201.00.3000, HTSUS, as it is not dog equipment. Therefore, the correct classification for the
merchandise described in NY 891581 is 4201.00.6000, HTSUS.
HOLDING
The applicable subheading for the reflective cat collar, will be 4201.00.6000, HTSUS,
which provides for “saddlery and harness for any animal (including traces, leads, knee pads,
muzzles, saddle cloths, saddle bags, dog coats and the like), of any material: other.”
The general, column 1 rate of duty for subheadings 4201.00.6000, HTSUS, is 2.8% ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the
most recent HTSUS and the accompanying rates are provided on the internet at
www.usitc.gov/tata/hts/.
A copy of this ruling letter should be attached to the entry documents filed at the time the
goods are to be entered. If the documents have been filed without a copy, this ruling should be
brought to the attention of the CBP officer handling the transaction.
EFFECT ON OTHER RULINGS
New York Ruling letter N891581, dated November 1, 1993 is hereby REVOKED in
accordance with the above analysis.
In accordance with 19 U.S.C. 1625(c), this ruling will become effective 60 days after
publication in the CUSTOMS BULLETIN.
Sincerely,
Allyson Mattanah for
Craig T. Clark, Director
Commercial and Trade Facilitation Division
CC: NIS Vikki Lazaro