CLA-2 CO:R:C:G 083457 NLP
Mr. Bernard D. Liberati
Morris Friedman & Co.
320 Walnut Street
Philadelphia, Pa. 19106
RE: Tariff classification of inflatable pool mattresses
Dear Mr. Liberati:
This is in response to your inquiry of November 26, 1988, on
behalf of Sunco Products, Inc., requesting a tariff
classification for inflatable pool mattresses under the
Harmonized Tariff Schedule of the United States (HTSUS).
Descriptive literature was submitted.
FACTS:
The subject merchandise is two inflatable pool mattresses.
Model #R-8547 is called the Printed Rayon Surf Rider. It is 45
inches by 29 inches and it is surrounded by a rope and grommets.
The second mattress is model #R-8572, the Rayon Surf Rider. It
is 72 inches by 30 inches and it is also surrounded by a rope and
grommets. Both mattresses are manufactured in Taiwan.
ISSUE:
What is the HTSUS tariff classification of the inflatable
pool mattresses?
LAW AND ANALYSIS:
Classification of merchandise under the HTSUS is governed by
the General Rules of Interpretation (GRI's), taken in order. GRI
1 provides that classification is determined in accordance with
the terms of the headings and relevant section or chapter notes.
Subheading 3926.90.7500 provides "for other articles of
plastics: pneumatic mattresses and other inflatable articles,
not elsewhere specified or included". Based on the fact that the
articles in question are made of rayon and not plastic, they
cannot properly be classified wi
-2-
Heading 6306 provides for "Tarpaulins; awnings and
sunblinds; tents; sails for boats, sailboards or landcrafts;
camping goods". Indented under this heading is subheading
6306.41.0000, which provides for pneumatic mattresses made of
cotton and 6306.49.0000, which provides for pneumatic mattresses
made of other textile materials. The Explanatory Notes, which
are the official interpretation of the Harmonized Tariff Schedule
at the international level, provide guidance as to the types of
pneumatic mattresses included in Heading 6306. Explanatory Note
5 to heading 63.06 states:
(5) camping goods. This group includes canvas buckets,
water bags, wash basins, ground-sheets; pneumatic
mattresses, pillows and cushions; hammocks.
Based on the Explanatory Notes it appears that the subheading
covers the types of mattresses one would bring along on a camping
trip to sleep or sit on. The instant mattresses are not of this
type; they are designed as floats to be used in swimming pools.
Thus, the rayon mattresses do not appear to fall within
subheading 6306.49.0000.
Heading 6307 provides for other made up textile articles.
The Explanatory Notes to heading 6307 state that this heading
includes made up articles of any textile materials which are not
included more specifically in other headings of Section IX or
elsewhere in the Nomenclature. The rayon pool floats are not
included more specifically in other HTSUS headings and would,
therefore, be classifiable within Heading 6307.
HOLDING:
The Printed Rayon Surf Rider and the Rayon Surf Rider are
classifiable in 6307.90.9050, which provides for other made up
textile articles, including dress patterns: Other: Other, other.
The applicable rate of duty is 7% ad valorem.
Sincerely,
John Durant, Director
Commercial Rulings Division