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HQ 954577


March 23, 1994

CLA-2 CO:R:C:F 954577 ALS

CATEGORY: CLASSIFICATION

TARIFF NO.: 4016.10.0000

Mr. Peter Beckett
Quattro International
2239 Old Middlefield Rd.
Suite E
Mountain View, CA 94043

RE: Furniture Glides from England

Dear Mr. Beckett:

This is in reference to your letter of June 16, 1993, regarding furniture glides made of natural rubber. Your request was referred to this Office by our New York Seaport Area Office.
Your letter was a follow-up to your previous letter to which our New York Seaport Area Office responded in ruling NY 886081, dated June 11, 1993. That letter dealt with the classification of glides made of synthetic rubber coated with PTFE.

FACTS:

The articles under consideration are furniture glides used as load bearing pads under furniture to facilitate its movement. The glides are in the form of discs of various diameters, in thickness of approximately 1/4 inch. The discs are made of natural rubber coated with polytetrafluoroethylene (PTFE).

Issue:

What is the classification of furniture glides made of natural rubber coated with PTFE?

LAW AND ANALYSIS:

Classification of merchandise under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) is governed by the General Rules of Interpretation (GRI's) taken in order.

GRI 1 provides that the classification is determined first in accordance with the terms of the headings and any relative section and chapter notes. If GRI 1 fails to classify the goods and if the headings and legal notes do not otherwise require, the remaining GRI's 1 are applied, taken in order.

We noted that the products under consideration are furniture glides which are designed to bear the weight of the furniture to which they are applied and to facilitate the movement of such furniture from place to place. The glides in the instant request are stated to be made of natural rubber.

In NY 886081 you were advised that furniture glides of synthetic rubber were classifiable in subheading 4016.99.5050, HTSUSA. Subsequent to the issuance of that ruling we learned that the factual premise for that ruling differed from what was stated in the ruling, i.e. the furniture glides were cellular synthetic rubber rather than synthetic rubber.

In considering your current request, we have assumed that the natural rubber glides which are the subject of this ruling, are made of cellular natural rubber.

Based on such conclusion we note that furniture glides of cellular rubber, whether the rubber is natural or synthetic, are classifiable under the same tariff subheading.

HOLDING:

Furniture glides of cellular rubber, whether the rubber is natural or synthetic, are classifiable in subheading 4016.10.0000, HTSUSA, which provides for other articles of vulcanized rubber other than hard rubber, of cellular rubber. Articles so classified are subject to a general rate of 4.2 percent ad valorem.

Sincerely,

John Durant, Director
Commercial Rulings Division

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