CLA-2-66:S:N:N:HO6 REH

Rain or Shine, Inc.
2545 Cavell Avenue North
Golden Valley, MN 55427

Attention: Larry Friedman

RE: The tariff classification of umbrellas from China.

Dear Mr. Friedman:

In your letter dated January 2, 1998, you requested a tariff classification ruling.

Pictorial information sheets describing a "SpunBrella" and a "TuneBrella" were submitted for our consideration. The umbrellas will feature woven man-made fabric or clear plastic skins over a non-collapsible metal shaft and standard construction characteristics. They will be available in various dome sizes, colors, and decorative designs and patterns. The detachable handle of the "TuneBrella" incorporates an AM/FM radio, and a battery driven device built into the handle of the "SpunBrella" enables the dome to rotate with musical accompaniment. The umbrellas will include "Clear PVC Protective Sheaths."

The applicable subheading for the "SpunBrella" and "TuneBrella," will be 6601.99.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Umbrellas and sun umbrellas (including walking-stick umbrellas, garden umbrellas, and similar umbrellas): Other: Other... The rate of duty will be 8.2 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Sincerely,


Michael D'Ambrosio
Service Port Director
St. Albans, Vt.