CLA-2-48:RR:NC:SP:234 L80975

Ms. Lisa Kelly
KC Pet Products LLC
12503 S.E. Division Street
Portland, Oregon 97236

RE: The tariff classification of disposable, absorbent pads for use in pet carriers, from China.

Dear Ms. Kelly:

In your letter dated November 15, 2004, you requested a tariff classification ruling. Product literature accompanied your request.

The item in question, which you state is made “mostly of paper products,” is a rectangular-shaped disposable pad designed to be placed in the bottom of a pet carrier. It is said to provide comfort to the animal being transported, and to absorb any “mishaps” that may occur.

The pad features a rigid core made of paperboard enveloped by a sheet of plastic “bubble wrap.” The core is in turn enveloped by absorbent material of a kind normally used to make disposable diapers and sanitary napkins. Based on the information you have provided, it is assumed that this material consists of paper pulp and/or paper blended with super-absorbent polymers, with an outer covering of porous nonwoven fabric. So that it can be cleanly and easily grasped for disposal, one end of the pad incorporates an attached plastic pull-tab handle designed to extend out through the wire opening of the carrier door.

The product will be offered in three sizes (small, medium and large) to fit different types of carriers. It will be packaged, together with an information sheet or flyer, in plastic bags containing a set of three like sizes.

The applicable subheading for the above-described pet-carrier pads will be 4818.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other (than certain enumerated) household, sanitary or hospital articles, of paper pulp, paper, cellulose wadding or webs of cellulose fibers. The rate of duty will be Free.

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 Carl Abramowitz at 646-733-3037.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division