The tariff classification of water sport tow ropes from China

N212137 April 27, 2012 CLA-2-95:OT:RR:NC:N4:424 CATEGORY: Classification TARIFF NO.: 9506.29.0080 Mr. Shay O’Reilly West Marine Products 500 Westridge Drive Watsonville, CA 95076 RE: The tariff classification of water sport tow ropes from China Dear Mr. O’Reilly: In your letter dated March 29, 2012, you requested a tariff classification ruling. Two samples of water sport tow ropes, SKU #10363877 (part # 2099050) and SKU #1177518 (part #6304.5.00.1), were received with your inquiry. The first item, SKU #10363877, is labeled as “Waterski Series Straight Line.” It is a 70’ tow rope which is looped on either end and is specifically rated for towing riders on water skis and inflatable tubes. It is made up of multiple polypropylene monofilaments which have been braided and cut to length. The rope is constructed with multiple take-off sections on the line, allowing it to be shortened during water ski competitions for different courses. Shortening the line’s length increases the difficulty of running the course around buoys during competition. One end of the rope features a “Quick Connect Woggle,” which is a sliding plastic clip with a hook on its end that allows for the quick attaching and separating of the tow rope to water ski handles or an inflatable tube. The second item, SKU #1177518, is a 60’ yellow tube tow rope which has loops on either end and is designed for towing riders on inflatable tubes. It is made up of multiple polypropylene monofilaments which have been braided and cut to length. Furthermore, it is labeled as “Heavy Duty Tube Tow Rope,” with the packaging stating the item is rated for only towing inflatable tubes carrying up to a maximum of four riders. Any other use may cause rope failure. Both samples will be returned to you. The applicable subheading for the water sport tow ropes, SKU #10363877 and SKU #1177518, will be 9506.29.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Articles and equipment for general physical exercise, gymnastics, athletics, other sports…or outdoor games…; Water skis, surf boards, sailboards and other water-sport equipment; parts and accessories thereof: Other…Other." 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 the World Wide Web at http://www.usitc.gov/tata/hts/. Your letter also mentions two other tube tow ropes for which no samples were provided, SKU #379230 / part #6301.5.00.1 and SKU #7926660 / part #6306.6.00.1. Your inquiry does not provide enough information for us to give a classification ruling. Your request for a classification ruling should include samples of the items in their retail packaging as imported. In addition, please provide any additional advertising and marketing information for each item. When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you. 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 James Forkan at (646) 733-3025. Sincerely, Thomas J. Russo Director National Commodity Specialist Division