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NY 851405


May 09, 1990

CLA-2-39:S:N:N3D:221 851405

CATEGORY: CLASSIFICATION

TARIFF NO.: 3921.13.5000; 3921.19.0000

Ms. M. Madeline Martinez
Danke International Ltd.
Park Avenue Atrium
237 Park Avenue, 21st Floor
New York, NY 10017

RE: The tariff classification of camping mats from Belgium, the Netherlands, West Germany and South Korea.

Dear Ms. Martinez:

In your letter dated March 23, 1990, which was received in this office on April 11, 1990, you requested a tariff classification ruling.

Included in your letter was a catalog depicting a large variety of mats. The mats illustrated in the first few pages appear to be in the form of rectangular sheets which have not been further processed such as by having the edges rounded, hemmed or beveled. Some sheets are made entirely of foamed polyurethane. Others are made entirely of foamed polyethylene. Another group is made from a layer of foamed polyurethane laminated to a layer of foamed polyethylene. For the purposes of this reply, it is assumed that the "belts" which are described in the literature are not sewn or attached to the mats, but are separate components which are merely slipped over the rolled-up mats in order to keep them from unrolling.

The applicable subheading for the mats in the form of rectangular sheets which have not been further worked, when made completely of polyurethane, or when bonded to polyethylene but in chief weight of polyurethane, will be 3921.13.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other plates, sheets, film, foil and strip, of plastics, cellular, of polyurethane, other. The rate of duty will be 4.2 percent ad valorem.

The applicable subheading for the mats in the form of rectangular sheets which have not been further worked, when made completely of foamed polyethylene, or when bonded to polyurethane but in chief weight of the polyethylene, will be 3921.19.0000, HTS, which provides for other plates, sheets, film, foil and strip, of plastics, cellular, of other plastics. The rate of duty will be 6.6 percent ad valorem.

The catalog illustrates other mats, including some made with a layer of faomed plastics combined with an aluminum layer. Other mats have rounded edges and have been combined with textile materials. Some have included pillows. Three samples of camping mats, not identified as to style number, were included with the letter. These samples include textile, aluminum and plastic components.

Your inquiry does not provide enough information for us to give a classification ruling on the remaining articles. Your request for a classification ruling should include a breakdown by both weight and value for each component in the mats. For any articles with a layer of aluminum, specify whether the aluminum is in the form of a separate foil layer or whether it has been vacuum coated onto a plastic film. In all cases, the cost and weight of the aluminum should be shown separately from the cost and weight of the material onto which it is coated. The cost of all textile components should be shown separately. Each request should be limited to no more than 5 items of the same class or kind.

The samples submitted with your request are being returned. If you wish a ruling on these products, please resubmit them, identified as to style number, with the complete breakdowns requested above. Describe how they are used, and especially whether the openings are meant for the insertion of a cushion or whether the user will fit himself into the opening and use the top textile layer as a blanket.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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