CLA-2-56:RR:NC:TA:350

Ms. Vivian Giddens
Penn Racquet Sports
306 South 45th Avenue
Phoenix, AZ 85043

RE: The tariff classification of needleloom felt material, for use in the manufacture of tennis balls, from either China or Thailand.

Dear Ms. Giddens:

In your letter dated August 17, 2007, you requested a tariff classification ruling.

The instant samples, which were marked “11037” and “11084”, respectively, consist of loosely woven textile scrims that have had textile fibers needled through and then, built up, to form a substantial felt material. This construction is, by definition a needleloom felt. You state that this fabric is composed of a 45% wool/45%nylon/10% polyester man-made fiber blend. The material weighs 18-20 ounces per square yard and will be imported as roll goods.

While you suggest that classification is proper in tariff subheading 5602.29.0000 which provides for other felt, not impregnated, coated, covered or laminated, of textile materials, other than wool or fine animal hair, this is not correct. As it appears that this material has been needled through a woven textile scrim, this product is more specifically provided for as a needled felt as indicated below.

The applicable subheading for the material will be 5602.10.9090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for needleloom felt and stitch-bonded fiber fabrics, … of other than wool or fine animal hair. The duty rate will be 10.6 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Deborah Walsh at 646-733-3044.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division