CLA-2-87:S:N:N1:101-873356

Mr. Frederick D'Agostino
Smith International Enterprises, Ltd.
20600 Chagrin Blvd., Suite 400
Shaker Heights, Ohio 44122

RE: The tariff classification of an automobile trunk cover from China

Dear Mr. D'Agostino:

In your letter dated April 10, 1992 you requested a tariff classification ruling. You have submitted a sample of the cover.

The cover consists of a "sandwich" of two fabrics: 50 percent nylon and 50 percent PVC. The product measures approximately 35 1/2 inches by 41 1/2 inches and has two nylon straps having VELCRO ends sewn at the top edge. In addition, two wooden dowels are sewn into the bottom of the product to add weight during use.

The cover is designed to be solely or principally used with motor vehicles. The VELCRO straps are used to secure the product to the bottom portion of the trunk of an automobile. Upon opening the trunk, the product is pulled out and draped over the rear panel and bumper. The purpose of this cover is to prevent the soiling of an individual's clothing when he (or she) is leaning over and reaching inside the trunk to insert or retrieve various articles. You indicate that it is your intention to market this product in the retail, wholesale, and premium markets, and that various printing arrangements may be used. For example, one version would have a corporate logo printed on one side, and "HELP", etc. on the other side. The printing arrangement may be as follows:

1. With no printing 2. Printing only on the nylon side 3. Printing only on the PVC side 4. Printing on both sides

The applicable subheading for the the automobile trunk cover, with or without the printing, will be 8708.99.5085, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of motor vehicles. The rate of duty will be 3.1 percent ad valorem.

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