The tariff classification of a Massage Pad from Hong Kong Dear Mr. Milne:In your letter, dated July 29, 1999, you requested a tariff classification ruling.Model #HPM-970 is a 13" x 13" massaging pad. It contains 2 electric motors located at both ends of the pad to create an even massage within the unit. There are two heat settings to customize your treatment for a gentle or energetic massage. The heating element is located only on one side of the pad. Included with the pad is a 12 Volt DC adapter, sponge, and textile cover. Your literature gives approximately the same space and emphasis to the massage and heating features. We estimate that the massage and heating components are roughly equivalent in cost and in importance to the average purchaser. The massage classification appears later in the HTS, noting Explanatory Note 3(c) to the General Rules of Interpretation.The applicable subheading for this item will be 9019.10.2035, Harmonized Tariff Schedule of the United States (HT

NY E85115 August 19, 1999 CLA-2-90:RR:NC:MM:105 E85115 CATEGORY: Classification TARIFF NO.: 9019.10.2035 Mr. Mark J. Milne Kaz Incorporated One Vapor Trail Hudson, NY 12534 RE: The tariff classification of a Massage Pad from Hong Kong Dear Mr. Milne: In your letter, dated July 29, 1999, you requested a tariff classification ruling. Model #HPM-970 is a 13” x 13” massaging pad. It contains 2 electric motors located at both ends of the pad to create an even massage within the unit. There are two heat settings to customize your treatment for a gentle or energetic massage. The heating element is located only on one side of the pad. Included with the pad is a 12 Volt DC adapter, sponge, and textile cover. Your literature gives approximately the same space and emphasis to the massage and heating features. We estimate that the massage and heating components are roughly equivalent in cost and in importance to the average purchaser. The massage classification appears later in the HTS, noting Explanatory Note 3(c) to the General Rules of Interpretation. The applicable subheading for this item will be 9019.10.2035, Harmonized Tariff Schedule of the United States (HTS), which provides for electrical massage apparatus, which is not battery powered, but powered by a separate AC to DC adapter. The rate of duty will be free. 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, contact National Import Specialist James Sheridan at 212-637-7037. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division COMMENT1