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