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NY C87350




May 21, 1998

CLA-2-84:RR:NC:1:103 C87350

CATEGORY: CLASSIFICATION

TARIFF NO.: 8479.89.9797

Mr. Ernesto Bustamante
William F. Joffroy, Inc.
PO Box 698
Nogales, AZ 85628-0698

RE: The tariff classification of a ratchet tie down from Mexico

Dear Mr. Bustamante:

In an undated letter on behalf of North American Manufacturing Corp. which we received on April 27, 1998 you requested a tariff classification ruling.

Two samples of ratchet tie downs were submitted with your inquiry. The tie downs are used to secure cargo to the bed of a truck or trailer and prevent it from shifting or moving. The units basically consist of a length of braided polypropylene rope, a plastic housing containing a combination ratchet gear-spool and a spring operated pawl mechanism, and two rubber coated metal hooks. One hook is directly attached to the housing, while the other is attached to one end of the rope. The ratchet mechanism prevents the rope from slipping after it has been tightened. The pawl can be manually pushed back to release the tension on the rope so that the tie down can be removed.

In your letter you stated that your client will ship all of the tie downs' components, which are of United States origin, to a maquiladora located in Mexico. There the various components will be assembled together to produce the tie downs, labelled with the country of origin, and packaged. The completed tie downs will then be shipped back to the United States.

The U.S. Customs Service has previously ruled that ratchet-type tie downs are mechanical appliances classifiable in heading 8479 - see Ruling Letter HQ 089411 dated June 10, 1991. Accordingly, the applicable subheading for the ratchet tie downs described above will be 8479.89.9797, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other: other: other: other. The rate of duty will be 2.7 percent ad valorem. In addition, importations of these tie downs may be eligible for a reduction in duty if the requirements of subheading 9802.00.80, HTS, are met.

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 Alan Horowitz at 212-466-5494.

Sincerely,

Robert B. Swierupski
Director,

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