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NY L87572





October 4, 2005

CLA-2-84:RR:NC:N1:106 L87572

CATEGORY: CLASSIFICATION

TARIFF NO.: 8424.89.7090

Ms. Donna L. Bade
Sandler, Travis & Rosenberg, P.A.
225 W. Washington Street
Chicago, IL 60606

RE: The tariff classification of various “Mr. Clean Autodry” automotive cleaning appliance carwash kits from China.

Dear Ms. Bade:

In your letter dated August 23, 2005 you requested a tariff classification ruling. You submitted a sample and descriptive literature with your request.

The merchandise at issue is various “Mr. Clean Autodry” automotive cleaning appliance carwash kits. All versions of the carwash kits are put up in retail packaging when being imported. The sample you submitted is for the “Auto Channel Mr. Clean Autodry Pro Series”. This kit consists of a pistol-grip “Autodry” dispersing appliance, a 200 ml bottle of Starter Soap with Dry Rinse Polymer, a Starter Filter, a wash mitt made from cotton artificial fur, a plastic polypropylene threaded coupling assembly, a plastic handled wheel brush with plastic bristles and a Swiffer Duster. You indicate that the coupling assembly contains no valve components. The kit is retail packaged in a plastic carrying case. Other kits have the following configurations:

Club Kit “Mr. Clean Autodry Pro Series”: This kit contains a 200 ml bottle of soap, a 600 ml refill bottle of soap, one pistol-grip cleaning appliance, a Starter Filter, a refill filter, wash mitt, coupling assembly and one wheel brush. The kit is packaged in a plastic carrying case.

Retail Kit “Mr. Clean Autodry Pro Series”: This kit contains a 200 ml bottle of soap, one pistol-grip cleaning appliance, a Starter Filter, wash mitt and coupling assembly. The kit is packaged in a plastic carrying case.

Club Kit “Mr. Clean Autodry”. This kit contains a 600 ml club bottle of soap, one refill filter and one pistol-grip cleaning appliance.

Costco Club Kit “Mr. Clean Autodry”. This kit contains two 600 ml bottles of soap, one pistol-grip cleaning appliance and two refill filters. The kit is packaged in a plastic carrying case.

For the submitted sample, the cleaning appliance, filter, connector assembly, wash mitt, plastic carrying case, wheel brush and Swiffer Duster are made in China, while the soap is made in Vietnam. The countries of origin are labeled as such on the retail packaging. The soap is formulated in such a way so as to promote a sheeting action during the rinsing action. The filter uses an ion exchange technology to remove impurities from the final rinse water to eliminate spotting or streaking. For tariff purposes, the “Autodry” units would be considered sets for retail sale, with the essential character being imparted by the pistol grip “Autodry” appliance.

The “Autodry” appliance functions through a structure of internal tubing. The whole device is connected to a typical garden hose. Water is introduced into three separate tubes within the device and an exterior selector valve directs the flow of water out of the device. The first tube is directed straight through the appliance and out of one of the three nozzles on the face of the “Autodry” device. The second tube is directed past the soap reservoir where a venturi pump is used to create a vacuum and add the soap into the stream of water. The soap/water mixture exits the device through a second nozzle on the front of the device. The third tube directs the water through the filter before exiting through the third nozzle on the front of the device. There is a flow washer in the filter path to limit the water pressure as it passes through the filter to less than 50 psi.

In operation, the filter is inserted into the bottom of the appliance and then the reservoir is filled with the recommended liquid soap solution. The device is connected to a water supply by an ordinary garden hose. The water begins to flow through the appliance when a flow valve in the form of a toggle switch at the rear of the device is flipped on. Before that step, the dial at the rear of the device is rotated to the rinse setting in order to wet the surface of the vehicle. The stream that issues from the device during the rinse cycle appears from all available evidence to be in the form of a projection or dispersion of water and not in the form of a spray, as those terms are commonly understood. The next step involves selecting the soap setting and projecting a mixture of soap and water on to the surface to be cleaned. After this step, the dial is once again turned to the rinse setting to wash away excess soapsuds. The final step is to select the “Mr. Clean Autodry” setting. This setting sprays de-ionized water which has been routed through the filter and which combines with the polymer remaining on the cleaning surface to result in a spot-free finish when the surface has dried. Judging by the nozzle apertures in the face of the device, only the “Mr. Clean Autodry” setting will result in a spray. The rinse and soap setting apertures will result in a projection or dispersion of the water, water/soap streams.

The applicable subheading for the “Mr. Clean Autodry” automotive cleaning appliance carwash kits will be 8424.89.7090, Harmonized Tariff Schedule of the United States (HTS), which provides for other mechanical appliances for projecting, dispersing or spraying liquids or powders. The rate of duty will be 1.8 percent 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 Patrick Wholey at 646-733-3013.

Sincerely,

Robert B. Swierupski
Director,

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