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NY 888683




CLA-2-89:S:N:N1:106-888683

CATEGORY: CLASSIFICATION

TARIFF NO.: 8907.10.0000

Mr. Poul V. Jensen
Viking Life-Saving Equipment (America), Inc. 1625 North Miami Avenue
Miami, FL 33136

RE: The tariff classification of inflatable life rafts from Denmark.

Dear Jensen:

In your letter dated July 20, 1993 you requested a tariff classification ruling. Your submitted drawings, fabric specifications and samples, and descriptive literature.

There are several varieties of inflatable life rafts in question, ranging from 4-person to 50-person sizes. Each has two buoyancy chambers made of nylon webbing coated with natural rubber. Each unit also has a canopy made of the same material. Some of the rafts may be hand-launched while the larger variety may be launched by a davit. These rafts have a self-contained inflation mechanism, comprising a bottle of carbon dioxide and a release cap actuated by pulling on a length of cord. The rafts also feature a hydrostatic release unit which automatically inflates the raft should it be submerged more than 4 meters. All items are packed in reinforced fiberglass containers. The imported life rafts are intended solely for the purpose of emergency at sea (e.g., during a ship wreck) and contain U. S. Coast Guard- mandated safety equipment such as rocket flares, water, rations and the like.

You state that the life rafts are for "safety use only and are not used for transporting people". You also state that you believe that heading 8903 of the Harmonized Tariff Schedule (HTS) applies to these inflatable life rafts. It should be noted that heading 8903, HTS, applies to yachts and other vessels (including inflatables) for pleasure or sports, as well as row boats and canoes. Inasmuch as these life rafts do not meet this description, classification in heading 8903 is not appropriate.

The applicable subheading for the inflatable life rafts will be 8907.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other floating structures...inflatable rafts. The rate of duty will be 3.8 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

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