Mr. Ronald Neal
Deringer Consulting
3665 Dove Rd.
Port Huron, MI 48060

RE: The tariff classification of racing scull oar components from China.

Dear Mr. Neal:

In your letter dated May 5, 2009, you requested a tariff classification ruling on behalf of your client Concept 2, Inc. A description and photos were submitted.

Two components of oars, to be used with racing sculls, were described in your request. According to your comments on the telephone, the two components will not be imported together. The first component is the blade for the oars, part number 804PP. The blade is produced from the following materials: 50% cured epoxy resin, 25% glass microsphere filler, 19% carbon fibers and 6% urethane based paint. The second component is a racing scull oar shaft, part 323. The shaft is composed of 60% carbon fibers and 40 % cured epoxy resin.

The applicable subheading for the blade for the oars, part number 804PP, will be 3926.90.3000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics and articles of other materials of headings 3901 to 3914: other: parts for…racing shells,… The rate of duty will be 4.2% ad valorem. The applicable subheading for the racing scull oar shaft, part 323 will be 6815.10.0000, HTSUS, which provides for articles of…other mineral substances (including carbon fibers,…)not elsewhere specified or included: nonelectrical 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 Mark Palasek at (646) 733-3013.


Robert B. Swierupski
National Commodity Specialist Division