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NY L80194




October 29, 2004

CLA-2-05:RR:NC:2:231 L80194

CATEGORY: CLASSIFICATION

TARIFF NO.: 0511.99.2000; 2309.10.0090

Mr. Jim Reynolds
John A. Steer Co.
28 S. 2nd Street
Philadelphia, PA 19106

RE: The tariff classification of dog chews from Brazil

Dear Mr. Reynolds:

In your letter dated August 20, 2004, you requested a tariff classification ruling on behalf of your client, the Transmundo Company of Miami, FL.

The products in question consist of certain rawhide dog chews, identified by 4-digit code numbers and described as follows:

Munchy Rollers (Code 2520) are chewable sticks, 5 inches long by 10 mm wide, made from rawhide, rice flour, salt, colorants and flavoring. These sticks are packed in 0.9 liter polyethylene jars of 360 grams, net, each containing 50 pieces.

Dental Chews for smaller dogs (Code 2523) are rectangular rawhide chips, 40 mm by 2.5 mm, which have been coated with sodium fluoride. These chips are packed in polyethylene jars of 115 grams, net, each containing about 15 pieces.

Mini Prairie Bone (Code 2530) is a 100 percent rawhide dog chew in the form of a knotted bone, 10-12 cm long. These bones weigh about 60 grams each, net, and are individually shrink-wrapped and labeled for retail sale.

Chew Sticks X 20 (Code 2531) consist of chew sticks, 4.5 inches long by 8-9 mm. These sticks, manufactured in assorted colors, contain rawhide (min., 80 percent) and rice flour. They are shrink-wrapped with labels in packs of 20 pieces per pack of 115 grams, net.

Munchy Flats X 20 (2532) are individually colored chew strips, 6 inches long by 3-4 mm, made from rawhide (min., 80 percent) and rice flour. These sticks are packed in a PVC bag holding 20 pieces, totaling 190 grams, net.

The applicable subheading for Munchy Rollers will be 2309.10.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for preparations of a kind used in animal feeding, dog or cat food, put up for retail sale, other. The rate of duty will be free.

The applicable subheading for the Dental Chews, Mini Prairie Bone, Chew Sticks and Munchy Flats 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.

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 Thomas P. Brady at 646-733-3030.

Sincerely,

Robert B. Swierupski
Director,

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