CLA-2-56:RR:OT:NC:N3:351
Mr. Peter J. Fitch
Fitch, King, LLC
250 Moonachie Road, 5th floor
Moonachie, NJ 07074
RE: The tariff classification of polypropylene rope from China
Dear Mr. Fitch:
In your letter dated October 26, 2010, you requested a tariff classification ruling on behalf of your client, General Work Products, of Jefferson, La.
You submitted an 18” piece of 3-ply, Z-twist polypropylene rope with a diameter of 1-1/2”. The outer covering of each ply is filament yarns, but the bulk of the cord is the core, comprised of textile polypropylene strip. You state that the strip exceeds 25.4 mm in width in its unfolded and untwisted condition; in its twisted condition, it does not exceed 5 mm in apparent width. Our examination of the sample indicates that the strips are fibrillated, that is, split longitudinally.
While the strips may have been non-fibrillated when the manufacturing process began, as you state, one of the methods by which plastic strips may be fibrillated is the physical twisting during the manufacturing process and this is probably how these became fibrillated. Therefore, as your merchandise is comprised of fibrillated polypropylene strip, it cannot be classified as non-fibrillated cord of subheading 5607.49.10, Harmonized Tariff Schedule of the United States (HTSUS), as you suggest.
The applicable subheading for the three-strand twisted rope will be 5607.49.2500, HTSUS, which provides for twine, cordage, ropes and cables, whether or not plaited or braided: Of polyethylene or polypropylene: Other: not braided or plaited: other. The general rate of duty will be 5.3% ad valorem + 9.8 cents per kg.
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 the World Wide Web at http://www.usitc.gov/tata/hts/.
Your sample will be returned.
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 Mitchel Bayer at (646) 733-3102.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division