CLA-2-44:OT:RR:E:NC:2:230

Mr. Paul J. Aguirre
Woodstock International, Inc.
1821 Valencia St.
Bellingham, WA 98229

RE: The tariff classification of hardwood sanding blocks from China

Dear Mr. Aguirre:

In your letter dated May 12, 2009 you requested a tariff classification ruling.

The ruling was requested on hardwood sanding blocks. A photograph and a description were provided. The sanding block is composed of an ergonomically shaped hardwood block body, a steel plate, a brass knob, a knurled mechanism and a felt pad. The sandpaper is not included. The brass knob is attached to the mechanism, which when turned, opens up a space between the hardwood body and the steel plate. The ends of a piece of sandpaper are inserted into the space and secured against the felt pad. The felt pad, the steel plate and the hardwood body support the sandpaper when used.

The subject sanding block is a composite good composed of different materials. The essential character of this sanding block is imparted by the hardwood body, which plays a significant role in the functioning of this product and provides the bulk of the product.

The applicable subheading for the hardwood sanding block described above will be 4417.00.8090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for tools, tool bodies, broom or brush bodies and handles, of wood, other (than certain enumerated products). The rate of duty will be 5.1 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 Paul Garretto at (646) 733-3035.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division