CLA-2-94:OT:RR:NC:N4:433

Pam Berry
General Manager
Marisol International, LLC
871 Ridgeway Loop, Suite 203
Memphis, TN 38120

RE: The tariff classification of wooden sofa parts from Vietnam.

Dear Ms. Berry:

In your letter dated March 30, 2010, you requested, on behalf of Albany Industries, a tariff classification ruling.

Part # 1 is referred to as a SEATSTRETCH2418 used in the manufacture of a sofa. The seat stretch is a wooden slat that is curved on the top and straight edged at the bottom, with a notch cut at the wider end. Its stated dimensions are approximately 24 1/8 inches long by 3 7/8 inches wide by 7/8 of an inch thick. After importation the seat stretch is used to support the bottom part of the frame of the sofa by means of connecting the front rail/slat to the notched seat stretch. This part is connected to the bottom, back and front sections of the wooden frame.

Part # 2 is referred to as a 4SPRINGLB2800R used in the manufacture of a sofa. The part is a wooden rectangular slat with two pre-drilled holes. The two holes are located at opposite ends of the slat. Its stated dimensions are approximately 28 inches long by 1 3/4 inches wide by 7/8 of an inch thick. After importation the part is used on the back, bottom part of the frame. This part is connected to the seat stretch via the pre drilled holes.

Part # 3 is referred to as a SPRINGRAILB400P used in the manufacture of a sectional sofa. The part is a wooden slat with a straight edge on one end and an angled edge on the other end, with a notch in the middle. The part is a back spring rail for a seat frame. Its stated dimensions are approximately 40 inches long by 1 3/4 inches wide by 7/8 of an inch thick. After importation the part will be incorporated into the frame to allow for sectional turns. This part is stapled to the seat stretcher and seat side rails, and after complete assembly of the sofa frame will be bolted to the back of the frame.

Part # 4 is referred to as a SPRINGRAILF0634 used in the manufacture of a sectional sofa. The part is a wooden slat with straight edges on both ends. There are no notches or pre-drilled holes in the slat. Its stated dimensions are approximately 6 3/4 inches long by 1 3/8 inches wide by 7/8 of an inch thick. After importation the part will be mounted onto the short side of the turned sectional. This part will have clips attached and will be stapled to the front rail. Photos indicate that the part is cut to size for the sectional frame.

The applicable subheading for the wooden sofa parts, will be 9401.90.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of wood.” The rate of duty will be free.

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 Neil H. Levy at (646) 733-3036.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division