N056438 N0 Ruling Active

The tariff classification of a plastic draft guard with textile cover and a metal over the door rack from China

Issued May 1, 2009 by U.S. Customs and Border Protection.

Tariff classification

HTS codes: 8302.50.0000, 3924.90.5600

Headings: 8302, 3924

GRI rules applied: GRI 3, GRI 3(b)

Product description

The submitted sample is identified as a Twin Draft Guard Insulating Device Offer, SKU# 53341. This item is consists of two Twin Draft Guards and a 5 Hook Over the Door Rack. The rack is described as a “free bonus” which is included with the importation and sale of the draft guards. Each of the two draft guards is comprised of four tubes made of ethylene vinyl acetate (EVA) plastic foam material and a cover made of cotton and polyester textile material. The consumer will attach two tubes to each other, end to end, by using an included plastic collar and do the same with the other two tubes included with each draft guard. As the result, each draft guard will ultimately be comprised of two long tubes which have been assembled from the four original smaller tubes. There are two side by side compartments that extend lengthwise through the textile cover so that the two assembled long tubes can be inserted into these compartments through slots at one end of the cover. The slots are then closed using the attached hook and loop fastener. The part of the textile cover that is between the two inserted tubes can then be slid under a door so that one tube is situated on one side of the door and the other tube is situated on the other side of the door. The draft guard can also be placed under a window so that the two tubes will be respectively situated on either side of the window. The draft guard is designed to guard against drafts, dust, odors, insects and noise. It can fit doors up to 2” wide and 36” long. It can be cut to size. The over the door rack is comprised of steel and has five hooks, located side by side on the bottom section, each of which has a porcelain knob or finial attached to the end. The five hooks are designed for the purpose of hanging towels, clothing or bathrobes. The top section of the item has two back hooks that are designed to fit over the top of a door, thereby keeping the rack in place. The rack fits doors up to 1.5” thick. Since the draft guards and

CBP rationale

The applicable subheading for the Twin Draft Guards will be 3924.90.5600, Harmonized Tariff Schedule of the United States (HTSUS), which provides for…other household articles…of plastics: other: other. The rate of duty will be 3.4 percent ad valorem. The applicable subheading for the 5 Hook Over the Door Rack will be 8302.50.0000, HTSUS, which provides for hat-racks, hat pegs, brackets and similar fixtures, and parts thereof.

Full text

N056438 May 1, 2009 CLA-2-39:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 3924.90.5600; 8302.50.0000 Ms. Francine Ramsey Hampton Direct Inc. P.O. Box 1199 Williston, VT 05495 RE: The tariff classification of a plastic draft guard with textile cover and a metal over the door rack from China Dear Ms. Ramsey: In your letter dated March 19, 2009, you requested a tariff classification ruling. The submitted sample is identified as a Twin Draft Guard Insulating Device Offer, SKU# 53341. This item is consists of two Twin Draft Guards and a 5 Hook Over the Door Rack. The rack is described as a “free bonus” which is included with the importation and sale of the draft guards. Each of the two draft guards is comprised of four tubes made of ethylene vinyl acetate (EVA) plastic foam material and a cover made of cotton and polyester textile material. The consumer will attach two tubes to each other, end to end, by using an included plastic collar and do the same with the other two tubes included with each draft guard. As the result, each draft guard will ultimately be comprised of two long tubes which have been assembled from the four original smaller tubes. There are two side by side compartments that extend lengthwise through the textile cover so that the two assembled long tubes can be inserted into these compartments through slots at one end of the cover. The slots are then closed using the attached hook and loop fastener. The part of the textile cover that is between the two inserted tubes can then be slid under a door so that one tube is situated on one side of the door and the other tube is situated on the other side of the door. The draft guard can also be placed under a window so that the two tubes will be respectively situated on either side of the window. The draft guard is designed to guard against drafts, dust, odors, insects and noise. It can fit doors up to 2” wide and 36” long. It can be cut to size. The over the door rack is comprised of steel and has five hooks, located side by side on the bottom section, each of which has a porcelain knob or finial attached to the end. The five hooks are designed for the purpose of hanging towels, clothing or bathrobes. The top section of the item has two back hooks that are designed to fit over the top of a door, thereby keeping the rack in place. The rack fits doors up to 1.5” thick. Since the draft guards and the rack are not put up together to meet a particular need or carry out a specific activity, these items are not considered to be “goods put up in sets for retail sale” within the meaning of General Rule of Interpretation (GRI) 3. Consequently, the draft guards and the rack must be classified separately. The draft guard and the rack are each considered to be a composite good within the meaning of GRI 3. It is the opinion of this office that the foam plastic tubes provide the draft guard with the essential character and the steel hooks provide the rack with the essential character within the meaning of GRI 3(b). The applicable subheading for the Twin Draft Guards will be 3924.90.5600, Harmonized Tariff Schedule of the United States (HTSUS), which provides for…other household articles…of plastics: other: other. The rate of duty will be 3.4 percent ad valorem. The applicable subheading for the 5 Hook Over the Door Rack will be 8302.50.0000, HTSUS, which provides for hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The rate of duty will be free. 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 Gary Kalus at (646) 733-3055. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division

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