HRL 081233 modified. Gloves; textile; rubber; plastics;essential; character

HQ 086502 March 15, 1990 CLA-2 CO:R:C:G 086502 HP CATEGORY: Classification Mr. Jonathan Shorts International Development Systems, Inc. Suite 520 735 15th Street, N.W. Washington, DC 20005 RE: HRL 081233 modified. Gloves; textile; rubber; plastics; essential; character Dear Mr. Shorts: This is in reference to HRL 081233 of September 19, 1989, with respect to our comments on the tariff treatment of hypothetical vinyl covered gloves under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). In HRL 081233, we discussed how we would approach the classification of gloves either cut and sewn from coated fabrics, or gloves which have a textile lining dipped in or impregnated with rubber or plastics. We stated that an analysis, under GRI 3(b), as to which component imparted the essential character of the gloves, would be required. After further deliberation, it is our opinion that this essential character analysis may not always be appropriate. We have enclosed a copy of a ruling germane to this question. We hope this is of help in eliminating any confusion resulting from our previous ruling. Pursuant to 19 C.F.R. 177.9(d)(1) (1989), HRL 081233 of September 19, 1989, is modified in conformity with the foregoing. Sincerely, John Durant, Director Commercial Rulings Division