Parker & Co.
4694 Coffee Port Road
Brownsville, TX 78521
RE: The tariff classification of leather from Germany
Dear Mr. Medina:
In your letter dated July 9, 2004, on behalf of your client L&L Leather, LLC, you requested a tariff classification ruling.
The leather will be imported as whole hides that are approximately 17 square feet each. Your letter indicates the dyed split leather crust will be covered with a pigmented aqueous based urethane. The desired grain pattern is imparted by a mold used in the finishing process. Your letter does not indicate the source of the leather. For purposes of this rulings we will assume the leather is bovine.
Your correspondence indicates that it is your position this product is classifiable under 4107.99.5000, HTSUS. Leather that is further prepared after tanning or crusting, imported in the form of whole hides and skins of bovine (including buffalo) or equine animals, is classifiable under subheadings 4107.11 through 4107.19, HTS. The tariff subheading you cite, 4107.99.50, covers the same type of leather but in a form other than whole hides and skins.
The applicable subheading for the leather will be 4107.19.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for leather further prepared after tanning or crusting, including parchment-dressed leather, of bovine (including buffalo) or equine animals, without hair on, whether or not split, other than leather of 4114: whole hides and skins: other of bovines, and a unit surface area not exceeding 28 square feet: other: fancy. The duty rate will be 3.6 percent ad valorem.
The question of classification and country of origin for the leather parts that will be cut in a Foreign Trade Zone is being referred to the Office of Regulations and Rulings, Bureau of Customs and Border Protection, 1300 Pennsylvania Avenue, N.W., Washington D.C. 20229. A ruling will be issued to you from that office.
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 Deborah Walsh at (646) 733-3044.
Robert B. Swierupski