The tariff classification of an "Umbra-Lite" from Taiwan.

NY A86834 September 6, 1996 CLA-2-66:RR:NC:5:353 A86834 CATEGORY: Classification TARIFF NO.: 6601.99.0000 Mr. Walter Dorfman Walter Scott Int'l. Corp. 1683 Winchester Rd. P.O. Box 1270 Bensalem, PA 19020-4510 RE: The tariff classification of an "Umbra-Lite" from Taiwan. Dear Mr. Dorfman: In your letter dated August 17, 1996 you requested a tariff classification ruling. You have submitted with your request three pictures of umbrellas that will be imported. The "Umbra-Lite" as illustrated is primarily an umbrella, with its handle containing a switchable battery operated light. It is designed to illuminate the path and surroundings for its user and to signal their presence to other pedestrians and vehicular traffic. The "Umbra-Lite" as the pictures illustrate does not have a self-folding telescopic shaft. The Umbra Lite is a composite article whose components are prima facie classifiable under different headings of the tariff schedule. The headings at issue refer to part only of the materials contained in the composite good and, according to GRI 3(a), are regarded as equally specific, making resort to GRI 3(b) necessary. GRI 3(b) states that if composite goods cannot be classified in accordance with GRI 3(a), they shall be classified as if they consisted of the material or component which gives them their essential character. The umbrella portion of the article performs the principle function of protection against the rain. The umbrella portion is the most identifiable, recognizable and marketable feature of the article and you indicate will be so marketed, advertised and sold by your client. The flashlight incorporated in the handle of the umbrella serves a minor role, its use limited to hours of the dark and at the discretion of the user. Accordingly it is the opinion of this office that the rain umbrella component imparts the essential character of the article. The applicable subheading for the Umbra-Lite umbrella will be 6601.99.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for umbrella and sun umbrellas (including walkingstick umbrellas, garden umbrellas and similar umbrellas): Other: Other. The rate of duty will be 8.2 percent ad valorem. 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 Martin Weiss at 212-466-5881. Sincerely, Roger J. Silvestri Director National Commodity Specialist Division