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NY 807591




March 14, 1995

CLA-2-56:S:N:N6:351 807591

CATEGORY: CLASSIFICATION

TARIFF NO.: 5609.00.3000

Mr. Robert Stankiewicz
Frank W. Winne and Son Inc.
44 North Front Street
Philadelphia, PA 19106

RE:The tariff classification of various braided 8-strand mooring lines (ropes), from Korea.

Dear Mr. Stankiewicz:

In your letter dated February 28, 1995 you requested a tariff classification ruling.

You are requesting a ruling on three separate sizes of "mooring lines," all of which are made of 8-strand braided nylon rope which can range from 7 to 12 inches in circumference (2¬ to 4 inches in diameter), with a canvas covered eye at each end that can range from 2 to 6 feet in diameter. The mooring lines will be imported in three lengths: 600 feet, 720 feet and 1,200 feet. You have indicated the following with regard to the three lengths in which these products are imported:

1.The 600 foot mooring line is the size required by U.S. vessels.

2.The 720 foot mooring line is the size required by foreign vessels.

3.The 1200 foot mooring line is to be used as a tow line, and represents the approximate distance required between vessels when towing.

In an earlier ruling request to which we replied in ruling number NY 805098 of December 19, 1994, you provided letters from your customers, marine suppliers who stated, for 720-foot 8-strand mooring lines with 6-foot canvas eyes, made of polypropylene rather than nylon:

The rope is used for mooring large vessels to the dock, the 720 foot lengths are required due to the fact that most vessels are approximately 600 ft. in length and covers the distance when mooring the vessel fore to aft to stabilize it, leaving 120 feet slack to move with the tides. Please also note the dock may be 50 feet or so from the mooring kevel on the boat requiring extra rope length.

As to the 6 foot canvas covered eye at each end of the rope. This is needed to hook onto the dock kleat and the kevel on the vessel. This 6 foot canvas covered eye is never cut off.

You state that the canvas covered eyes are identical in construction to the one addressed by ruling NY 805098. In that ruling we stated, based on a photograph you submitted with the ruling request, that the eyes appeared to have been spliced in a permanent manner and were covered with a canvas sheath.

You also indicate that "By no means are these eyes going to be cut off upon arrival into the United States. The items which we purchase from Korea are brought in and sold as mooring lines and we must have canvas covered eyes on these ends."

The Explanatory Notes to the Harmonized Tariff Schedules (HTS) constitute the official interpretation of the nomenclature at the international level. The Explanatory Notes to heading 5609 indicate that this provision includes cordage cut to length and looped at one or both ends. The mooring lines at issue here are looped in a substantial way at both ends, and you have provided evidence that they are cut to the length in which they will actually be used to moor or tow vessels.

The applicable subheading for the three mooring lines described above will be 5609.00.3000, HTS, which provides for articles of...twine, cordage, rope or cables, not elsewhere specified or included; of man-made fibers. The rate of duty will be 8.6 percent ad valorem.

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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