Mr. Christopher Garcia
National Operations Manager
Kuehne + Nagel, Inc.
8200 Boggy Creek Road - Suite 600
Orlando, Florida 32824

RE: The tariff classification for graphite composite tubes from China.

Dear Mr. Garcia:

In your letter dated February 9, 2009, on behalf of Aldila, Inc. of Poway, California, you requested a tariff classification ruling for graphite composite tubes. You provided illustrative literature with product specifications for our review.

The graphite composite tubes consist of 5 surface finished tubes of 1 inch diameter cut into 4 different lengths (two pieces 4 inches long and one of each of the following lengths: 22 inches, 19 inches and 18 inches). The tubes will be assembled onto an electric golf caddy: two on the bottom, two on the body and one on the handle.

The applicable subheading for the graphite composite tubes will be subheading 6815.10.0000, HTSUS, which provides for: non-electrical articles of graphite or other carbon. 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 Frank Cantone at (646) 733-3038.


Robert B. Swierupski
National Commodity Specialist Division