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February 11, 1999

CLA-2-63:RR:NC:TA:352 D86794

CATEGORY: CLASSIFICATION

TARIFF NO.: 6307.90.9989; 3926.90.9880

Mr. Edward B. Ackerman
Grunfeld, Desiderio, Lebowitz & Silverman LLP 245 Park Avenue
33rd Floor
New York, NY 10167-3397

RE: The tariff classification of cooler components from China, Taiwan or Thailand.

Dear Mr. Ackerman:

In your letter dated January 22, 1999, on behalf of Outer Circle products, you requested a tariff classification ruling. The samples are being returned as requested.

Your request for a classification ruling was submitted for insulated cooler components for a Y2K Injection Molded Cooler. After importation into the United States the cooler components will be attached to a rigid plastic cooler. One cooler component is made of three layers of material. The outer layer consists of a nylon or polyester woven fabric with rubber/plastc trimming. The middle layer of this product is a layer of cellular foam. The third layer which forms the interior of the cooler component is manufactured from textile material. The cooler component on the front exterior side features a zippered pocket. It has a textile shoulder strap. This component is a part and is not considered an unfinished cooler since it does not have the essential character of the finished cooler.

The second cooler component is constructed of three layers of material. The outer layer consists of woven fabric which has been coated, covered or laminated with a layer of plastic which is said to be polyvinyl chloride. The plastic has been determined to be noncellular. The plastic surface of this material faces outward. The middle layer of this product is a layer of cellular foam. The third layer which forms the interior of the cooler component is manufactured from a nonwoven textile material. The cooler component on the front exterior side features a zippered pocket. It has a textile shoulder strap. This component is a part and is not considered an unfinished cooler since it does not have the essential character of the finished cooler.

The third cooler component is constructed of three layers of material. The outer layer consists of plastic sheeting material. The middle layer of this product is a layer of cellular foam. The third layer which forms the interior of the cooler component is manufactured from textile material. The cooler component on the front exterior side features a zippered pocket. It has a textile shoulder strap. This component is a part and is not considered an unfinished cooler since it does not have the essential character of the finished cooler.

The applicable subheading for the first two cooler components will be 6307.90.9989, HTS, which provides for other made up articles...Other. The rate of duty will be 7 percent ad valorem.

The applicable subheading for the plastic cooler component will be 3926.90.9880, HTS, which provides for other articles of plastics and articles of other materials of 3901 to 3914: Other: Other, other. The rate of duty will be 5.3 percent ad valorem.

Articles which are classifiable under subheadings 6307.90.9989 and 3926.90.9880, HTS, which are products of Thailand are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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 Tytelman at 212-637-7092.

Sincerely,

Robert B. Swierupski
Director,

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