The tariff classification of a “Doff n’ Donner” kit from China

N198409 January 23, 2012 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3926.90.9980 Ms. Fay Szeto Albatrans, Inc. 2805 W. El Segundo Blvd. Suite 3 Hawthorne, CA 90250 RE: The tariff classification of a “Doff n’ Donner” kit from China Dear Ms. Szeto: In your letter dated December 22, 2011, on behalf of FC International Inc., you requested a tariff classification ruling. A sample of a three piece “Doff n’ Donner” kit was included with your letter and is being returned as you requested. The kit is designed for use by persons who need help in donning and removing compression stockings. The main component of the kit is the Doff n’ Donner, a ribbed cylindrical double-walled sleeve or tube made of thermoplastic elastomer that slips over the limb. The other components are a Donner pole and a power suction base that mounts the pole securely to the floor. The Doff n’ Donner tube measures approximately 5 ½ inches in length and 4 ½ inches in outer diameter and is filled with soapy water. The motion of the liquid inside the inner and outer walls of the tube causes it to glide easily over the limb. To don the stocking, the user rolls the stocking onto the Doff n’ Donner tube, inserts his foot into the tube and glides the tube over his limb. The gliding action unrolls the stocking onto the leg. The ribbed surface of the tube may then be used to smooth any wrinkles on the stocking. To remove the stocking, the user inserts his foot into the empty Doff n’ Donner tube, glides the tube to the top of the stocking, folds the top of the stocking onto the tube, and glides the tube down the leg, thus rolling the stocking down off the leg and back onto the tube. The stocking may be kept in this position on the tube until it is time to don it again. The stocking may be rolled onto the tube either by hand, or by using the Donner pole with suction base. The pole is made of molded plastic and measures approximately 22 ½ inches in length. The suction base holds the pole in a secure upright position while the stocking is placed over the pole. When the Doff n’ Donner tube is rolled over the stocking that is mounted on the Donner pole, the stocking rolls onto the tube in position for donning. The pole may also be used for unrolling the stocking from the tube after it has been doffed. At this time, the three components – the Doff n’ Donner tube, the Donner pole and the suction base – will be imported packaged together. In the future, some of the components may be imported separately as replacement parts. The applicable subheading for the Doff n’ Donner kit, as well as for any of the three components imported separately, will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem. 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 Joan Mazzola at (646) 733-3023. Sincerely, Thomas J. Russo Director National Commodity Specialist Division