Classification of a "Sport Sling," a nylon and woodapparatus for carrying folding chairs and other beachaccessories; formerly called the "Beach Sling"; NYRL 866045

HQ 952749 May 12, 1993 CLA-2 CO:R:C:T 952749 BC CATEGORY: Classification TARIFF NO.: 6307.90.9986 Charles D. Frey CDF Trade, Inc. 314 Fifth Avenue South Naples, Florida 33940 RE: Classification of a "Sport Sling," a nylon and wood apparatus for carrying folding chairs and other beach accessories; formerly called the "Beach Sling"; NYRL 866045 Dear Mr. Frey: This responds to your letter of September 30, 1992, concerning the referenced product. By such letter, you informed us that since you received a classification ruling for your "Beach Sling" product, three changes have occurred. First, you have incorporated under the name CDF Trade, Inc. Second, you have changed the name of your product to "Sport Sling." Third, you have decided to produce your product in China rather than the Philippines. You requested a ruling to reflect these changes. FACTS: The merchandise at issue consists of nylon woven fabric with two wooden dowels, one inserted into each end. It features three pockets, web handles, a detachable shoulder strap, and a detachable pouch stuffed with foam. When the "Sport Sling" is not in use for transporting, it can be opened to sit and/or lie upon. The merchandise at issue was the subject of New York Ruling Letter (NYRL) 866045, dated September 5, 1991. At that time, and under that ruling, it was called the "Beach Sling" and was classified under subheading 6307.90.9490, Harmonized Tariff Schedule of the United States Annotated (HTSUSA) (subsequently changed to subheading 6307.90.9480, HTSUSA). You reported that for reasons related to trademark considerations, the "Beach Sling" was renamed the "Sport Sling." ISSUE: What is the proper classification for the "Sport Sling"? LAW AND ANALYSIS: According to NYRL 866045, the product was classifiable as "Other made up articles . . . Other, Other, Other" under subheading 6307.90.9490, HTSUSA, dutiable at 7% ad valorem. (You indicated in your letter that this was subsequently changed to subheading 6307.90.9480, HTSUSA.) Under the current tariff, your product is classifiable under subheading 6307.90.9986, HTSUSA. This subheading covers: "Other made up articles [of textiles] . . . . : Other: Other: Other," carrying a duty rate of 7% ad valorem. This change is not due to a change in the product, but to a change in the numbering of the tariff. Finally, as you indicated, there is no visa requirement for articles classified under subheading 6307.90.9986, HTSUSA. HOLDING: The "Sport Sling" is classifiable under subheading 6307.90.9986, HTSUSA. There is no visa requirement. Sincerely, John Durant, Director Commercial Rulings Division