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

Mr. Bryon Brown
Lifetime Products
Freeport Center Bldg., D-11
P.O. Box 160010
Clearfield, UT 84404

RE: The tariff classification of kayak seat backs and carry straps from China

Dear Mr. Brown:

In your letter dated August 17, 2011, you requested a tariff classification ruling.

Photographs and drawings were provided with your letter. The first product is identified as a seat back for a kids kayak. The seat back functions as a backrest and is sold as an accessory for the kayak. It is composed of polyethylene plastic foam and has a polyester textile strap with a clip at each end to secure it to the kayak. The second product is a seat back for an adult kayak. This seat back/backrest is made of ethylene vinyl acetate (EVA) foam and polyethylene sheet, both covered with polyester fabric. The seat back has a polyester textile strap with a clip at each end to secure it to the kayak. The third product is a carrying strap or harness for a kayak. The strap is made of polyester textile and is designed so that it can be wrapped around a kayak. In the center portion of the strap there is a steel bar to use as a handle to carry the kayak. Nylon buckles are used to attach the strap around the kayak.

The applicable subheading for the kayak seat backs will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the kayak carrying strap/harness will be 6307.90.9889, HTSUS, which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem.

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