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NY C85620




March 27, 1998

CLA-2-40:RR:NC:SP:221 C85620

CATEGORY: CLASSIFICATION

TARIFF NO.: 4016.94.0000

Mr. Herbert E. Harris II
Harris Ellsworth & Levin
The Watergate
2600 Virginia Avenue, N.W., Suite 1113
Washington, D.C. 20037-1905

RE: The tariff classification of inflatable boat and dock fenders from England.

Dear Mr. Harris:

In your letter dated March 17, 1998, on behalf of Dunlop Limited, England, and Wood Corporation, Louisiana, you requested a tariff classification ruling.

The inflatable fenders are used as a cushion between boats or between a boat and dock to prevent abrasion and lessen the shock of impact. The fenders are made from a woven nylon substrate laminated on both sides with neoprene rubber. The rubber/textile material weighs over 1500 grams per square meter, with the textile component comprising less than 50 percent by weight of the material. This construction is considered to be a Chapter 40, HTS, rubber material for classification purposes.

The applicable subheading for the inflatable boat and dock fenders will be 4016.94.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of vulcanized rubber other than hard rubber...boat or dock fenders, whether or not inflatable. The rate of duty will be 4.4 percent ad valorem.

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 Joan Mazzola at 212-466-5580.

Sincerely,

Robert B. Swierupski
Director,

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