CLA-2-87:RR:NC:MM:101 H87607

Ms. Barbara Y. Wierbicki
Tompkins & Davidson, LLP
One Astor Plaza
1515 Broadway
New York, NY 10036-8901

RE: The tariff classification of a Backseat Tray Organizer from China

Dear Ms. Wierbicki:

In your letter dated February 6, 2002 you requested a tariff classification ruling on behalf of your client, Avon Products, Inc.

You submitted a sample of a Backseat Tray Organizer, PP236843. You state that the item is a rear seat, drop down tray automobile organizer which measures approximately 15" wide by 11" long by 3" deep. The organizer utilizes four straps of nylon webbing material, each of which incorporates "hook and loop" fasteners to form two horizontal belts for attachment to the rear seat. The front and back of the item is constructed of panels that are completely covered by nylon textile fabric. The organizer also features a double zipper closure along three sides and a center "hook and loop" tab closure. In the open position, the front panel drops down to form a tray, which is held in place by an adjustable cord with toggle. The interior features four pockets incorporated as part of the rear wall panel.

You state that you believe that the Backseat Tray Organizer is correctly classified as HTS 8708.59.5060. That Harmonized Tariff Number does not exist in the 2002 Harmonized Tariff Schedule of the United States.

The applicable subheading for the Backseat Stray Organizer will be 8708.99.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other...Other. The rate of duty will be 2.5% 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 646-733-3008.


Robert B. Swierupski
National Commodity
Specialist Division