CLA-2-39:OT:RR:NC:N4:421

Mr. George R. Tuttle, III
The Law Offices of George R. Tuttle
One Embarcadero Center, Suite 730
San Francisco, CA 94111-4044

RE: The tariff classification of an inflatable mattress

Dear Mr. Tuttle:

In your letter dated August 20, 2010, on behalf of The Sports Authority, you requested a tariff classification ruling.

The sample provided with your letter is identified as a “Memory Foam Raised Airbed with Textile Cover,” SKU 27496480. The airbed is an inflatable mattress made of 14 gauge polyvinyl chloride (PVC) plastic sheeting with a zippered top cover made of polyester cotton blend fabric. The zipper allows the fabric cover to be removed for washing and then reattached. A foam plastic cushion consisting of a 0.5 inch memory foam sheet laminated to a 0.5 inch standard foam sheet fits between the plastic shell and the top cover to provide additional cushioning. The mattress includes an inflation pump. You provided a value breakdown showing the cost of the PVC shell at 48%, the plastic foam at 33%, the textile cover at 12% and the pump at 7%.

The applicable subheading for the Memory Foam Raised Airbed with Textile Cover, SKU 2746480, will be 3926.90.7500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics…pneumatic mattresses and other inflatable articles, not elsewhere specified or included. The general rate of duty will be 4.2 percent ad valorem.

You did not identify the country of origin. The rate of duty provided above is the rate applicable to this product when it is made in a country with which the United States has Normal Trade Relations. 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 http://www.usitc.gov/tata/hts/.

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 Joan Mazzola at (646) 733-3023.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division