CLA-2-73:OT:RR:NC:N1:113

Mr. Michael S. McCullough
Vandegrift Forwarding Company Inc.
9317 Cheshire Road
Sunbury, OH 43074

RE: The tariff classification of garment hangers from China, Korea and Taiwan

Dear Mr. McCullough:

In your letter dated June 16, 2008, on behalf of Econoco Corporation, you requested a tariff classification ruling. A sample of each style of garment hanger for which you are requesting a ruling was submitted for our review.

You indicate in your letter that the merchandise is garment hangers used by retail clothing stores and garment salesmen. Style numbers PC16/W-SW and PC17/W-LH are made of plastic coated flat steel. Style numbers SKT/12, SKT/12-LH, LIN/16, LIN/16-LH, SLD/16, SLD/16-LH, SLC/16, SLC/16-LH, DSA/9 and DP/14 are made of chrome-plated 3.4 mm steel wire.

You indicate that style numbers SKT/12, LIN/16, SLD/16, SLC/16, DSA/9 and PC16/W-SW are used by retail clothing stores to display garments for sale. The hangers are removed by the cashier and reused by the store. SKT/12 is a 12 inch skirt hanger, LIN/16 is a 16 inch lingerie hanger, SLD/16 is a 16 inch blouse and dress hanger, SLC/16 is a 16 inch combination hanger with vinyl cushion clips, DSA/9 is a 9 inch drop attachment and PC16/W-SW is a 16 inch non-slip hanger with a swivel hook.

Style numbers DP/14, SKT/12-LH, LIN/16-LH, SLD/16-LH, SLC/16-LH and PC17/W-LH are used by clothing salesmen for carrying and displaying their garment samples. These hangers have a loop hook that allows them to be threaded onto a diaper pin rod for ease of transport. DP/14 is a 14 inch diaper pin rod, SKT/12-LH is a 12 inch skirt hanger, LIN/16-LH is a 16 inch lingerie hanger, SLD/16-LH is a blouse and dress hanger, SLC/16-LH is a combination hanger with vinyl cushion clips and PC17/W-LH is a 17 inch non-slip hanger with a swivel hook.

In your letter, you suggest classification of the steel garment hangers under heading 7323, Harmonized Tariff Schedule of the United States (HTSUS), which provides for table, kitchen or other household articles and parts thereof, of iron or steel. However, these hangers are not principally used in the home, hotels, restaurants, boarding-houses, hospitals, canteens, barracks, etc., and are therefore not classified as household articles in heading 7323. Steel garment hangers principally used by retail clothing stores and garment salesmen for the display or transport of clothing are classified in heading 7326, which provides for other articles of iron or steel. The applicable subheading for garment hanger style numbers SKT/12, SKT/12-LH, LIN/16, LIN/16-LH, SLD/16, SLD/16-LH, SLC/16, SLC/16-LH, DSA/9 and DP/14 will be 7326.20.0020, HTSUS, which provides for other articles of iron or steel, articles of iron or steel wire, garment hangers. The rate of duty will be 3.9 percent ad valorem. The applicable subheading for garment hanger style numbers PC16/W-SW and PC17/W-LH will be 7326.90,8587, HTSUS, which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 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 Ann Taub at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division