CLA-2-67:OT:RR:NC:N4:415

Mr. Mark S. Davies
LG Sourcing, Inc.
1000 Lowe's Boulevard
Mooresville, NC 28144

RE: The tariff classification of artificial pine needle garland ties from China.

Dear Mr. Davies:

In your letter dated June 10, 2019, you requested a tariff classification ruling.

The product under review consists of 10 artificial pine needle garland ties. These ties are constructed from polyvinyl chloride (PVC) “pine needle” strips that are bound to the twisted wire core. They are intended to be used to fasten artificial pine garland to railings or other decorative projects.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the Harmonized Tariff Schedule of the United States (HTSUS) and are generally indicative of the proper interpretation of these headings. As per the ENs, heading 6702 covers “[a]rtificial flowers, foliage and fruit in forms resembling the natural products, made by assembling various parts (by binding, glueing, assembling by fitting into one another or similar methods).” As this product meets the requirements set forth by this heading and is not subject to any of the listed exclusions, classification within heading 6702 appears appropriate for these garland ties.

The applicable subheading for the artificial pine needle garland ties will be 6702.10.2000, HTSUS, which provides for “[a]rtificial flowers, foliage and fruit and parts thereof; articles made of artificial flowers, foliage or fruit: [o]f plastics: [a]ssembled by binding with flexible materials such as wire, paper, textile materials or foil, or by gluing or by similar methods.” The column one, general rate of duty is 8.4 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 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 Kristopher Burton at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division