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NY F83476




April 18, 2000

CLA-2-05:RR:NC:2:231 F83476

CATEGORY: CLASSIFICATION

TARIFF NO.: 0506.90.0020; 0506.90.0040; 0511.99.2000; 0511.99.3060

Ms. Sylvie Delwiche
TTM Petfood International SA
43 rue Cesar de Paepe
B-4683 Vivegnis
Belgium

RE: The tariff classification of dog chews from Belgium.

Dear Ms. Delwiche:

In your letter, dated February 18, 2000, you requested a classification ruling.

The products included in this inquiry are described as pet treats, unfit for human consumption as a result of the manufacturing processes with which they are prepared. Aside from maple syrup, which is added to some products as a flavoring, no ingredients are added during processing.

The pig ears, whether whole ears or bits, are dried extensively. Wafered pig ears are processed to remove all the fat contained in the ears and dried extensively. The wafered ears will be imported either plain or flavored with maple syrup.

Wafered pig feet will be processed to remove all fat, then dried for an extended period at 158 degrees Fahrenheit. Wafered pig feet may be imported either plain dried or flavored with maple syrup.

Wafered pig snouts will be processed to remove all fat, then dried for an extended period at 158 degrees Fahrenheit. Wafered pig snouts will be imported either plain dried or flavored with maple syrup.

Pork thighbones, shinbones, beef back and front cannon bones, full thighbones, shoulder bones, and kneecaps will be boiled and steamed, then dried to a white finish. These bones are fully cleaned, free of marrow or adhering meat. These bones may be imported plain dried or flavored with maple syrup.

Pork full thighbones, shinbones, beef back and front cannon bones, full thighbones, shoulder bones, and marrowbones, smoked, are cooked and smoked with natural wood smoke. Some marrow and adhering meat is left on the bone.

Dried bull and veal penises are cooked slowly at a low temperature and then dried for an extended period of time. No other ingredients are added during processing.

The applicable subheading for dried pig ears, whole, bits, or wafered, either plain or flavored, will be 0511.99.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for animal products not elsewhere specified or included, dead animals of chapter 1 or 3, unfit for human consumption, other, other, parings and similar waste of raw hides or skins; glue stock not elsewhere specified or included. The rate of duty will be free.

The applicable subheading for dried pig snouts (wafered, unflavored or flavored with maple syrup), dried pig feet (wafered, unflavored or flavored with maple syrup), and dried bull and veal penises, will be 0511.99.3060, HTS, which provides for animal products not elsewhere specified or included; dead animals of chapter 1 or 3, unfit for human consumption, other, other, products chiefly used as food for animals or as ingredients in such food, other. The rate of duty will be free.

The applicable subheading for pork thighbones and shinbones, plain white, beef back and front cannon bones, full thighbones, shoulder bones and kneecaps, plain white, will be 0506.90.0020, HTS, which provides for bones and horn-cores, unworked, defatted, simply prepared (but not cut to shape), treated with acid or degelatinized; powder and waste of these products, other, bones, crude, steamed or ground. The rate of duty will be free.

The applicable subheading for pork thighbones and shinbones, beef back and front cannon bones, full thighbones, shoulder bones and kneecaps, if flavored with maple syrup, will be 0506.90.0040, HTS, which provides for bones and horn-cores, unworked, defatted, simply prepared (but not cut to shape), treated with acid or degelatinized; powder and waste of these products, other, other. The rate of duty will be free.

With regard to the pork and beef bones, smoked and with some adhering meat, please provide samples and indicate what, specifically, renders these bones unfit for human consumption. Generally, food products such as bones with adhering meat, have human food uses in soups and similar dishes, and must be denatured in some way, as, for example, by the addition of ash or other denaturing ingredients, or otherwise rendered unsuitable for human consumption.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Thomas Brady at 212-637-7064.

Sincerely,

Robert B. Swierupski
Director,

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