CLA-2-95:OT:RR:NC:N4:424

Mr. Robert Grasing
Sandler, Travis & Rosenberg, P.A.
24 Smith Street Building 2, Suite 102
Pawling, NY 12564

RE: The tariff classification of ski bindings from the Czech Republic and China

Dear Mr. Grasing:

In your letter submitted December 14, 2018, you requested a tariff classification ruling on behalf of your client, K2 Sports LLC. You have submitted photographs and detailed product descriptions for each item in lieu of samples.

The first product at issue is identified as the MX Cell 14 TCx D Alpine Ski Binding, item S1802001010, manufactured in the Czech Republic. As detailed in your request, this binding is imported as a pair and specifically designed for use in alpine/downhill racing for racers between the ages of 10 and 13 weighing less than 120 kilograms. The bindings are mounted on to snow skis and are compatible with alpine ski boots. The bindings are designed for maximum power transmission between ski and boot with specialized technology to keep the skier’s boot perpetually centered during quick jolts. Some of the design features of the MX Cell 14 include a large contact area for a skier’s boot sole, top power transfer, and shock absorption. The step-in heel design increases the boot and ski connectivity for a longer period, even in extremely steep terrain, ensuring precise ski guidance until released.

The second product under consideration is identified as item B1804002018, the Cinch TS Blue XL Snowboard Ski Binding, manufactured in China. As detailed in your request, this binding is imported as a pair and is specifically designed for use in snowboarding. As described in the product literature, the specialized design provides more support to the outside of the foot, improving control and reducing fatigue, allowing a skier to ride longer and stronger. Additional features of this product include a durable rear-entry all-terrain nylon highback shape that allows a skier to quickly and easily strap in and a canted footbed angled inward to match a skier’s natural leg position during riding.

The applicable subheading for the MX Cell 14 TCx D Alpine Ski Bindings and the Cinch TS Blue XL Snowboard Ski Bindings will be 9506.12.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for snow-skis and other snow-ski equipment; parts and accessories thereof: ski bindings and parts and accessories thereof: other. The rate of duty will be 2.8 % ad valorem.

With regard to the rate of duty, the subject ski bindings are also provided for in Heading 9902, HTSUS. Subheading 9902.17.55, HTSUS, by virtue of legislative action, provides for a temporary reduction in the rate of duty for “[s]ki bindings (other than for cross-country skis), valued not over $55 each (provided for in subheading 9506.12.80).” The aforementioned ski bindings meet all of the prerequisites of this tariff provision. Accordingly, the ski bindings are entitled to beneficial treatment under HTSUS subheading 9902.17.55. The rate of duty for this subheading is Free. This rate only applies to articles entered on or before December 31, 2020.

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 https://hts.usitc.gov/current.

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 Roseanne Murphy at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division