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NY K86887




June 22, 2004
CLA-2-87:RR:NC:MM:101 K86887

CATEGORY: CLASSIFICATION

TARIFF NO.: 3926.90.9880, 8716.80.5090, 8716.90.5060

Ms. Maurine Cecil
American Shipping Company Inc.
400 Oceangate, Suite 1106
Long Beach, California 90802

RE: The tariff classification of the Total Trolley and accessories: Crates and Flexideck from China

Dear Ms. Cecil:

In your letter dated June 2, 2004 you requested a tariff classification ruling on behalf of your client Total Trolley LLC.

You submitted a sample as well as the Owner’s Guide and the “101 Uses” Booklet.

You state that this item will be imported in four versions: Trolley/ladder stand alone
Trolley/ladder with flexideck (made of plastic) Trolley/ladder with 3 crates (made of plastic) Trolley/ladder with 3 crates and flexideck (crates and flexideck made of plastic).

You further state that these parts (crates and flexideck) are sometimes shipped separately and require rulings as well.

The sample and booklets you submitted are the Trolley/ladder stand alone. This item is a multi-use product designed to function as a step ladder, furniture dolly, four-wheel cart and hand truck. Even though this item can be used as a non-wheeled device, its principal use is as a wheeled trolley.

The crate is foldable and made of plastic, holds up to 50 lbs. and instantly opens for use and collapses for storage. It attaches to the trolley/ladder in the hand truck mode by means of metal studs.

The Flexideck is made of plastic and provides a solid surface so that smaller objects can be carried. In the ladder mode, the Flexideck creates a handy work surface to hold tools, paint cans, etc.

The applicable subheading for the Crate will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: OtherOther. The rate of duty will be 5.3% ad valorem.

The applicable subheading for the Trolley/ladder stand alone 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. The rate of duty will be 3.2% ad valorem.

The applicable subheading for the Flexideck will be 8716.90.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Parts: OtherOther. The rate of duty will be 3.1% 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 646-733-3008.

Sincerely,

Robert B. Swierupski
Director,

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