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NY M81785




April 12, 2006

CLA-2-74:RR:NC:N1:113 M81785

CATEGORY: CLASSIFICATION

TARIFF NO.: 7418.19.2090

Mr. Joseph Hoffacker
Barthco Trade Consultants
The Navy Yard
5101 S. Broad Street
Philadelphia, PA 19112-1404

RE: The tariff classification of napkin rings from India

Dear Mr. Hoffacker:

In your letter dated March 16, 2006, on behalf of Urban Outfitters, Inc., you requested a tariff classification ruling.

The merchandise consists of two styles of Winter Jewel Napkin Rings. Each one is composed of 4 metal rings measuring 1.5 inches in diameter and fastened together by metal wire. The rings and wire are decorated with glass and acrylic beads. Item number 04120801AMBER is made of brass rings, brass wire, and pink, gold and clear beads. Item number 04120801TURQ is made of brass rings, steel wire, and silver and clear beads. The weight of the brass is greater than the steel in this napkin ring.

The applicable subheading for the napkin rings will be 7418.19.2090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for table, kitchen or other household articles and parts thereof, of copperother, other, of copper-zinc base alloys (brass), other. The regular duty rate will be 3 percent ad valorem.

Articles classifiable under subheading 7418.19.2090, HTS, which are products of India may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term "GSP".

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 James Smyth at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,

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