CLA-2-87:RR:NC:MM:101 G88707

Mr. Karl F. Krueger
Danzas AEI Customs Brokerage Services
29200 Northwestern Highway
Southfield, MI 48034

RE: The tariff classification of a Two-Wheeled Trolley, a Camera Rain Cover, Shoulder Straps, and “Modi-vers” - polyethylene foam boards from China

Dear Mr. Krueger:

In your letter dated March 9, 2001 you requested a tariff classification ruling on behalf of your client, The Tiffen Co.

You submitted samples of five items intended for use with photographic cases.

The first item is a two-wheeled trolley used to assist in carrying equipment from place to place. It resembles the two-wheeled carts used to carry luggage. It is constructed of an aluminum frame with plastic handles and plastic wheels.

The second item is a camera rain cover. It resembles a bag with a drawstring and is made of PU and PVC coated nylon fabric. On each side is a slit to allow the camera user to insert a hand to operate the camera without completely removing the cover.

The third and fourth items are shoulder straps that would be used with a camera bag. The straps are made of woven polypropylene and the pads are made of PVC and EPDM.

The last items are called “Modi-vers.” These are polyethylene foam boards laminated together in pairs. A polyester/nylon brushed fabric is then laminated around the boards and on each end of the boards a strip of hook-and-loop fabric with the hooks is attached so that half of the strip extends past the end of the board. The boards are inserted inside a camera case to divide the interior into sections. The hook fabric latches onto the inside surface of the bag to keep them in place.

In ruling on each of the five items we do so with the understanding that each will be imported without the camera case and not in the same shipment as the case.

The applicable subheading for the Shoulder Straps and the “Modi-vers” - foam boards will be 6307.90.9989, Harmonized Tariff Schedule of the United States (HTS), which provides for Other made up articles, including dress patterns: Other: Other: Other…Other: Other. The rate of duty will be 7% ad valorem.

The applicable subheading for the Two-wheeled Trolley will be 8716.80.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for Trailers and semi-trailers; other vehicles not mechanically propelled; and parts thereof: Other vehicles: Other…Other: Other. The rate of duty will be 3.2% ad valorem.

The applicable subheading for the Camera Rain Cover will be 9006.91.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Photographic cameras; photographic flashlight apparatus and flashbulbs other than discharge lamps of heading 8539; parts and accessories thereof: Parts and accessories: For cameras. The rate of duty will be 5.8% 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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division