CLA-2 CO:R:C:T 956038 CC
Hans Wurian
Design Salt North America
P.O. Box 1220
Redway, CA 95560
RE: Classification of a sleeping bag liner; HRL 954416;
Heading 6307
Dear Mr. Wurian:
This letter is in response to your inquiry, dated February
24, 1994, requesting the tariff classification of a sleeping bag
liner. A sample was submitted for examination.
FACTS:
You describe the merchandise at issue as a sleeping bag liner
for "mummy shaped (tapered) sleeping bags." It measures 95 inches
by 35 inches, but will be produced in a smaller size in the future.
It is designed in two versions: with a top opening only and with
an additional side opening. Both designs have a drawstring hood
and a "boxed foot." In addition, the liner comes with a "stuff
sack," a drawstring bag that holds the liner. This merchandise is
made in one of the following materials: 100 percent woven cotton,
100 percent silk, 100 percent cotton flannel, or 100 percent
polyester.
You state that this merchandise is designed specifically for
use as a liner or insert for sleeping bags, to add warmth, comfort,
and longevity to sleeping bags, and may be used as a replacement
for sleeping bags in warmer weather. The subject merchandise is
designed, manufactured, and advertised for use by campers and
backpackers.
ISSUE:
How is the subject merchandise classified under the Harmonized
Tariff Schedule of the United States Annotated (HTSUSA)?
LAW AND ANALYSIS:
Classification of merchandise under the HTSUSA is in
accordance with the General Rules of Interpretation (GRI's), taken
in order. GRI 1 provides that classification shall be determined
according to the terms of the headings and any relative section or
chapter notes.
Heading 6306, HTSUSA, provides for tarpaulins, awnings and
sunblinds; tents; sails for boats, sailboards or landcraft; camping
goods. Heading 6307, HTSUSA, provides for other made up articles.
In Headquarters Ruling Letter (HRL) 954416, dated September
30, 1993, we ruled on the classification of a sleeping bag liner
designed for additional warmth. We found in that ruling that the
liner was an accessory to a sleeping bag. Since accessories to
camping goods are not provided for in Heading 6306, we ruled that
the liner was not classifiable in that heading. Instead, the
merchandise of HRL 954416 was classified in Heading 6307.
The submitted merchandise is designed for use with sleeping
bags to provide additional warmth. It is therefore similar to the
merchandise of HRL 954416. Consequently, it is similarly
classified, in Heading 6307.
The drawstring bag is also classifiable in Heading 6307. It
is not more specifically provided for in another heading. In
addition, we have ruled that drawstring bags that are not specially
shaped or fitted are classifiable in Heading 6307. (See, e.g., HRL
954403, dated November 16, 1993.) The subject drawstring bag does
not have special features that suggest it is designed to hold
particular articles. Consequently, the drawstring bag is
classifiable in Heading 6307.
HOLDING:
Both the sleeping bag liner and the drawstring bag are
classified under subheading 6307.90.9986, which provides for other
made up articles, other, other, other, other, other.
The rate of duty is 7 percent ad valorem. No textile category is
currently assigned to merchandise classified under this subheading.
Sincerely,
John Durant, Director
Commercial Rulings Division