Mr. Robert B. Silverman
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP
399 Park Avenue, 25th floor
New York, NY 10022-4877

RE: The tariff classification of Roller Boltz Roller Skates, Style # TXBEK704ZZROL, from China

Dear Mr. Silverman:

In your letter dated August 9, 2007, on behalf of your client, BBC International, you requested a tariff classification ruling.

The sample submitted, Roller Boltz Roller Skates, are roller skates that are built into the sole of a sneaker. The child can engage the roller, allowing the roller skate to drop out of the bottom of the sneaker sole, thus allowing the child to roller skate. The roller in the sneaker can be disengaged and the roller will return to the inside of the sneaker’s sole, thus hiding the roller skates. This toy is put up for the amusement of children. In your letter, you indicated that the roller skates would be imported, assembled and disassembled. In our opinion, both items will be classified the same.

The applicable subheading for the Roller Boltz Roller Skates assembled and disassembled will be 9506.70.2010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Articles and equipment for general physical exercise, gymnastics, athletics, other sports... or outdoor games... parts and accessories thereof: Ice skates and roller skates…parts and accessories thereof: roller skates and parts and accessories thereof: attached to boots. The rate of duty will be Free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at

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 Thomas McKenna at 646-733-3025.


Robert B. Swierupski
National Commodity
Specialist Division