CLA-2-39:S:N:N3D:221 879329

Mr. Jim Reynolds
John A. Steer Co.
28 S. Second Street
Philadelphia, PA 19106

RE: The tariff classification of suspended ceiling systems from Belgium.

Dear Mr. Reynolds:

In your letter dated October 19, 1992, on behalf of Rulon Company, you requested a tariff classification ruling.

The ceiling system consists of polyvinyl chloride (PVC) sections and various components, among them stainless steel carriers that have holes and slots. The pictures of the PVC sections that you provided indicate that these sections have a uniform cross section along their entire length. The PVC sections fall into two general categories: those with a circular cross section, such as the "Curved Face Spacer," and those with more complex cross sections, such as the "Deep Straight Edge Strip," the "Curved Edge Strip," the "Perimeter Wall Trim," the "Carrier Connector" and the "Flat Faced Spacers." The systems will be imported either as complete units or as separate components. The method of importation will affect the classification. Classification of the PVC sections is dependent on whether they have been further worked. Drilling holes into the PVC sections prior to importation is an example of further working. Though there is no mention of any further working on the PVC sections, and no such processing is visible in your submitted illustrations, classification for sections which have been further worked is provided for your information.

The applicable subheading for the PVC ceiling system including all its components, when imported as an unassembled unit, will be 3925.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for builders' ware of plastics, not elsewhere specified or included, other. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the "Curved Face Spacer," whether or not further worked, when not imported as part of an unassembled unit, will be 3925.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for builders' ware of plastics, not elsewhere specified or included, other. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the PVC sections with a uniform cross section more complex than merely circular, when not further worked and not imported as part of an unassembled unit, will be 3916.20.0090, HTS, which provides for sticks and profile shapes, whether or not surface-worked but not otherwise worked, of plastics, of polymers of vinyl chloride.

The applicable subheading for the PVC sections with a uniform cross section more complex than merely circular, when further worked and not imported as part of an unassembled unit, will be 3925.90.0000, HTS, which provides for builders' ware of plastics, not elsewhere specified or included, other. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the stainless steel carrier, when not imported as part of an unassembled unit, will be 7222.40.6000, HTS, which provides for angles, shapes and sections of stainless steel, other. The rate of duty will be 5.3 percent ad valorem.

Your letter does not provide enough information for us to issue a ruling for the metal carriers and "Quick Action Hangers" when they are not imported as part of an unassembled unit. Before we can classify the metal carriers, we need to know the type of metal. If of steel, please provide a mill certificate showing the chemical composition or grade of steel. In addition, state the materials of which Quick-Action Hangers are composed.

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