CLA-2-39:S:N:N6:350 892139

Mr. Jerome Berger
Harper Group
1 World Trade Center, Suite 3973
New York, NY 10048

RE: The tariff classification of two coated/laminated fabrics, from Bangladesh.

Dear Mr. Berger:

In your letters dated July 20, and November 4, 1993, on behalf of Doel America Ltd., you requested a tariff classification ruling. The manufacturer is Bangladesh Chemical Industries, Ltd.

Two representative samples were submitted. The first one, black in color and identified on the sample as "Nimbus Foaming", consists of a 100% cotton knit substrate fabric that has been laminated to a cellular PVC plastics material. This PVC portion contains a thin skin top layer that has been embossed to simulate leather. The second item is similar in construction to the first, except that it contains a rose embossed floral design and contains no identifying style or quality number. While you did not indicate the weights of the two materials, both of them were informally analyzed by the New York Customs Laboratory and found to weight between 15 and 17 ounces per square yard. Additionally, while you indicated that the substrate fabrics of both samples are composed of man-made fibers, our laboratory found the substrates to be composed of cotton as we indicated above.

The applicable subheading for the two materials will be 3921.12.1910, 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, combined with textile materials, products with textile components in which vegetable fibers predominate by weight over any other single textile fiber. The duty rate will be 5.3 percent ad valorem. Articles classifiable under subheading 3921.12.1910, HTS, which are products of Bangladesh are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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