CLA-2 CO:R:C:M 088842 DFC
Mr. James L. Konski
International Randonneurs
Old Engine House No. 2
727 North Salina Street
Syracuse, New York 13208
RE: Medals, sports award
Dear Mr. Konski:
In a letter dated February 19, 1991, you inquired as to
the tariff classification under the Harmonized Tariff Schedule
of the United States Annotated (HTSUSA), of certain amateur
bicycling award medals manufactured in France.
FACTS:
Your organization, International Randonneurs, is the
American name for Randonneurs Mondiaux, an organization of
bicyclists consisting of 15 member countries. You inform us
that your organization acts as a voluntary coordinator for some
26 sponsoring bicycle clubs throughout the United States, and
is supported by volunteer help, token dues and contributions.
Also, your organization donates to their French coordinating
group only the small cost of materials, postage and shipping and
that most of their activities are subsidized by contributions.
The merchandise involved may be described as a flat base
metal sports award, round in shape, measuring 2 inches in
diameter and coated with various metallic colors. The medal has
a loop at its top. A jump ring or bail can be fitted into this
loop to enable the recipient to wear the medal as a pendant.
After importation these medals will be distributed by your
organization to the 26 sponsoring bicycle clubs throughout the
United States for bestowal upon winners of long-distance cycling
events.
ISSUE:
Do these medals qualify for an exemption from duty under
subheading 9807.00.40, HTSUSA?
LAW AND ANALYSIS:
Subheading 9807.00.40, HTSUSA, provides for free entry of
articles of metal (including medals, trophies and prizes), for
bestowal on persons in the United States, as honorary
distinctions by foreign countries or citizens of foreign
countries.
It is our understanding that although your organization,
International Randonneurs, coordinates distribution of the medals
to the successful U.S. cyclists, the qualifications for and
issuance of the medals is controlled by the central French club
(Randonneurs Mondiaux). In view of this fact, it is our position
that the bicycling award medals are entitled to free entry under
subheading 9807.00.40, HTSUSA.
HOLDING:
The bicycling ward medals are classifiable under subheading
9807.00.40, HTSUSA, and entitled to free entry.
Sincerely,
John Durant, Director
Commercial Rulings Division
6cc AD NY Seaport
1cc Lou Piropato NY Seaport
1cc DD Buffalo
cahill library/peh
088842