CLA-2-39:S:N:N3H:350 857399

Mr. Gary C. Lefebvre
Freudenberg Nonwovens Inc.
P.O. Box 48
Rooseveltown, N.Y. 13683

RE: The tariff classification of an imitation leather fabric for use in the manufacture of synthetic leather goods, from West Germany.

Dear Mr. Lefebvre:

In your letter dated October 5, 1990, you requested a tariff classification ruling. The sample submitted (Vol Rocco) consists of a needleloom fabric of 100 percent polyester man-made fibers that has been coated with an expanded polyvinyl chloride plastics material. This substrate fabric is, by construction, a felt for tariff purposes and not a "nonwoven" as indicated in your letter. You indicate that the PVC and textile comprise 80 and 20 percent by weight, respectively, and the total fabric weight is approximately 755 grams per square meter.

The applicable subheading for the fabric will be 3921.12.1100, Harmonized Tariff Schedule of the United States (HTS), which provides for other plates, sheets, film, foil and strip, of plastics, cellular, of polymers of vinyl chloride, products with textile components in which man-made fibers predominate by weight over any other single textile fiber,over 70 percent by weight of plastics. The rate of duty will be 4.2 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.


Jean F. Maguire
Area Director
New York Seaport