CLA-2-28:RR:NC:2:236 C83170

Ms. Sarah Keen
L.E. Coppersmith,Inc.
2041 Rosecrans Avenue, Suite 300
El Segundo, CA 90245

RE: The tariff classification of Dryshod Shoe Dryer/Deodorizer from Japan

Dear Ms. Keen:

In your letter dated January 6, 1998, on behalf of your client, Gerald Stockton Inc./ASO International, you requested a tariff classification ruling.

The sample submitted, Dryshod Shoe Dryer/Deodorizer, is a shoe insert made of silica gel, a reinforced polyester laminated with a non-woven cloth and an indicator label. Dryshod, when insert into a shoe overnight, absorbs the moisture from the shoe. Dryshod is packaged for retail sale in pairs.

Dryshod Shoe Dryer/Deodorizer is a composite good and is classified in accordance with the General Rules of Interpretation (GRI) under GRI 3(b). Silica gel is the component that gives this product its essential character. Therefore, the applicable subheading for Dryshod Shoe Dryer/Deodorizer will be 2811.22.1000, Harmonized Tariff Schedule of the United States, which provides for Other inorganic acids and other inorganic oxygen compounds of nonmetals: Other inorganic oxygen compounds of nonmetals: Silicon dioxide: Synthetic silica gel. The rate of duty will be 3.7 percent ad valorem.

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 V. Gualario at 212-466-5744.

Sincerely,

Robert B. Swierupski
Director
National Commodity
Specialist Division