BOR-7-07-CO:R:IT:C 112735 DEC

Ms. Sande S. Nowakowski, LCHB
Trans American CHB, Incorporated
2775 Broadway
Buffalo, New York 14227-1043

RE: Instruments of International Traffic; IIT; Truck Saddle; 19 U.S.C. 1322; 19 C.F.R. 10.41a.

Dear Ms. Nowakowski:

This is in reference to your June 30, 1993, correspondence with the Office of Regulations and Rulings - Carrier Rulings Branch in which you requested a ruling to classify truck saddles that are designed for holding truck cabs together to assist in their transport.

FACTS:

Hook Up, Incorporated, a Canadian company, uses "saddles" to connect new truck cabs piggy back while hauling them into the United States. The cabs are being imported into the United States and do not contain merchandise. Once the truck cabs are delivered to a dealer in the United States, they are shipped back to Hook Up's terminal to be re-used.

ISSUE:

Whether the described truck saddles may be considered instruments of international traffic within the meaning of 19 U.S.C. 1322(a) and section 10.41a of the U.S. Customs Regulations (19 C.F.R. 10.41a).

LAW AND ANALYSIS:

Title 19, United States Code, section 1322(a) provides that:

[V]ehicles and other instruments of international traffic, of any class specified by the Secretary of the Treasury, shall be excepted from the application of the customs laws to such extent and subject to such terms and conditions as may be prescribed in regulations or instructions of the Secretary of the Treasury.

19 U.S.C. 1322(a) (1992).

-2-

Title 19, Code of Federal Regulations, section 10.41a authorizes the Commissioner of Customs to designate other items as instruments of international traffic in decisions to be published in the weekly Customs Bulletin. Once designated as instruments of international traffic, these items may be released without entry or the payment of duty, subject to the provisions of 10.41a. 19 C.F.R. 10.41a(1) (1993).

To qualify as an "instrument of international traffic" within the meaning of 19 U.S.C. 1322(a) and the regulation promulgated pursuant thereto (19 C.F.R. 10.41a et seq.), an article must be used as a container or holder. The article must be substantial, suitable for and capable of repeated use, and used in significant numbers in international traffic. (See generally Headquarters Decisions 103232, 104766, 108084, 108658, 109665, and 109702).

Upon reviewing the request and accompanying documentation, we are of the opinion that the requirements of establishing instrument of international traffic status have been met. More specifically, the saddles in question appear to be substantial, suitable for and capable of repeated use, and used in significant numbers in international traffic.

HOLDING:

The saddles used to transport truck cabs piggy back are hereby designated as instruments of international traffic within the meaning of 19 U.S.C. 1322(a) and 19 C.F.R. 10.41a and may be released without entry or the payment of duty.

Sincerely,

Acting Chief
Carrier Rulings Branch