CLA-2 CO:R:C:T 088002 HP

4103.10.0000; 4105.12.0000

Dr. C.T. Stacey
Founder
Harrington Organization
P.O. Box 148
Tallassee, AL 36078-0148

RE: Skins; leather; goat; sheep; camel; tanned; wet blue; wetblue; hair; wool; pickled; dried; salted

Dear Dr. Stacey:

This is in reply to your letter of September 25, 1990, concerning the tariff classification of skins, imported from Saudi Arabia, under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).

FACTS:

The merchandise at issue consists of five types of wet blues and skins, described as follows:

Preparatio Skin Type Value n

Dried/Salt Domestic Wool Sheep Skin with Hair $8.00 ed

Dried/Salt Domestic Hair Sheep Skin with Hair $8.00 ed

Dried/Salt Domestic Goatskin with Hair $8.00 ed

Pickled Domestic Wool Sheep Skin, Hairless, $2.00/ft not Split

Pickled Domestic Hair Sheep Skin, Hairless $2.00/ft

Pickled Domestic Goatskin, Hairless $2.00/ft

Wet Blue Domestic Sheepskin, Hairless $2.50/ft You state that these wet blues and skins will be sold to factories manufacturing leather products.

ISSUE:

What is the correct classification of these skins under the HTSUSA?

LAW AND ANALYSIS:

Note 1(c) to Chapter 41, HTSUSA, excludes from classification therein hides or skins, with the hair or wool on, except for, inter alia, the sheep and goats at issue. Chapter 41 is therefore appropriate.

HOLDING:

As a result of the foregoing, the instant merchandise at issue is classified as follows:

Dried/Salted Wool & Hair Sheep Skins with Hair

... under subheading 4102.10.0000, HTSUSA, as raw skins of sheep or lambs (fresh, salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not with wool on or split, other than those excluded by note 1(c) to this chapter, with wool on. The applicable rate of duty is Free.

Dried/Salted or Pickled Goatskins with or without Hair

... under subheading 4103.10.0000, HTSUSA, as raw skins (fresh, salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not dehaired or split, other than those excluded by note 1(c) to this chapter, of goats or kids. The applicable rate of duty is Free.

Pickled Wool Sheep Skin, Hairless

... under subheading 4102.21.0060, HTSUSA, as raw skins of sheep or lambs (fresh, salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not with wool on or split, other than those excluded by note 1(c) to this chapter, without wool on, pickled, other, not split. The applicable rate of duty is Free.

Pickled Hair Sheep Skin, Hairless

... under subheading 4102.21.0030, HTSUSA, as raw skins of sheep or lambs (fresh, salted, dried, limed, pickled or otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not with wool on or split, other than those excluded by note 1(c) to this chapter, without wool on, pickled, hair sheep and cabretta skins. The applicable rate of duty is Free.

Wet Blue Sheepskin, Hairless

... under subheading 4105.12.0000, HTSUSA, as sheep or lamb skin leather, without wool on, other than leather of heading 4108 or 4109, pretanned or retanned but not further prepared, whether or not split, otherwise pretanned. The applicable rate of duty is 5 percent ad valorem.


Sincerely,

John Durant, Director
Commercial Rulings Division