Mr. Robert G. Marshall
444 Talleyrand Avenue, Suite B
Jacksonville, FL 32202
RE: The tariff classification of lashing gear from Taiwan
Dear Mr. Howe:
In your letter dated August 15, 2000, on behalf of Buffers USA Inc.,you requested a tariff classification ruling.
The merchandise is steel hardware used on board a container ship to tie down freight containers. There also appear to be a number of items, such as tools, which we suggest you request separately, with detailed information as to their use and composition. The Equalash System uses two rods, one turnbuckle and one deck fitting to secure 40-foot containers. The lashing rod/bars tie down the corner of the container to the deck. The turnbuckles tie down the lashing rod to the deck. The ISO deck socket is welded onto the deck to house the twistlock. D-rings and lashing eyes are welded to the deck to attach the turnbuckles. The extension hook extends the lashing bar to the turnbuckle.
The manual twistlocks, semi-automatic twist locks, midlocks and semi-automatic liftlocks lock the containers together when stacked on deck. Each of these items has been forged, but are further worked by having been galvanized. Hanging stackers are fitted to the bottom corners on the container when stacked on deck or in the holds of the ship. Bridge fittings tie containers together in top corners when stacked on deck. Stacking cones are used in between containers in the holds.
Dovetail twistlocks are a special type of twistlocks used on the decks of Ro-Ro ships to hold down containers. U-Frames are welded down to the deck to hold Dovetail twistlocks. Flush ISO sockets are used on Ro-Ro ships to house twistlocks.
In addition to the system itself, you have two items used to transport or store the twistlocks. Twistlock bins store the twistlocks. They are transportable by forklift truck. Flatracks of 20 and 40-foot lengths hold the twistlock bins.
The applicable subheading for the twistlock bins will be 8609.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for containers specially designed and equipped for carriage by one or more modes of transport. The duty rate will be free.
The applicable subheading for the flatracks and the other listed parts of the system will be 7326.90.8586, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other. The duty rate will be 2.9 percent ad valorem.
The question of the applicability of heading 9803.00.50, HTS, is being referred to the Office of Regulations and Rulings, U.S. Customs Service Headquarters, 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 James Smyth at 212-637-7008.
Robert B. Swierupski