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NY H84869




August 16, 2001

CLA-2-87:RR:NC:MM:101 H84869

CATEGORY: CLASSIFICATION

TARIFF NO.: 8716.80.5090

Mr. Ken Lacy
K E L International
1838 El Camino Real #222
Burlingame, California 94010

RE: The tariff classification of a Sports Caddy, Canoe/Kayak Tote and a PWC Dolly 24 from Taiwan

Dear Mr. Lacy:

In your letter dated August 7, 2001 you requested a tariff classification ruling.

You submitted literature describing a Sports Caddy, Canoe/Kayak Tote and a PWC Dolly 24.

The Sports Caddy is used to transport goods to the beach, for example. The caddy has two balloon-like wheels enabling it to traverse over sand, mud, and grass without sinking into this type of terrain. The caddy can carry coolers, beer kegs, sporting equipment, outdoor furniture, luggage and bags. The Sports Caddy has a rigid metal frame and is pulled (like an airport luggage cart) by an individual.

The Canoe/Kayak Tote is non-motorized, not a trailer, and is used by an individual to transport a canoe or kayak with ease over various types of terrain. It has a heavy-duty aluminum frame; 2 large detachable wheels with balloon tires; collapses for easy in-boat storage; and includes two 13 foot tie-down straps. You state in your brochure that this Tote can facilitate loading of the boat onto the roof racks of a car or van. The Tote is turned upside down on the trunk of the car or the rear of the van. The boat is placed between the Tote wheels. One end of the boat is grasped and slid up. The wheels will guide the boat onto the roof rack.

The PWC Dolly 24 is non-motorized, not a trailer, and is used for transporting a Jet Ski. The Dolly has four balloon wheels mounted to a frame. The Specification Sheet for this Dolly does not show any apparatus for hitching this Dolly to another vehicle. It appears from the submitted literature that the PWC Dolly 24 allows a person to move their Jet Ski with ease, for example, from the beach to the water.

The applicable subheading for the Sports Caddy, Canoe/Kayak Tote and the PWC Dolly 24 will be 8716.80.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for Trailers and semi-trailers: other vehicles, not mechanically propelled; and parts thereof: Other vehicles: OtherOther: Other. The rate of duty will be 3.2% 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 Robert DeSoucey at 212-637-7035.

Sincerely,

Robert B. Swierupski
Director,

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