CLA-2-39:OT:RR:NC:N4:421
Ms. Jennifer R. Diaz
Becker & Poliakoff
121 Alhambra Plaza, 10th Floor
Coral Gables, FL 33134
RE: The tariff classification of an iPad cover/stand from China
Dear Ms. Diaz:
In your letter dated July 24, 2012, on behalf of Marware, Inc., you requested a tariff classification ruling.
The sample submitted with your request, identified as the C.E.O. Hybrid, product AHHB1P, is a folding cover/stand for the iPad 2nd and 3rd generation. The C.E.O. Hybrid serves as a protective cover or jacket for the iPad. It measures approximately 7-1/4 inches by 9-1/2 inches in its closed condition and can be secured by means of a thin elastic strap sewn to the inside front cover. The rigid back is essentially flat with tabs that curve slightly inward so that the iPad can be secured into the tabs. The back section incorporates a small cut-out for the camera lens. The front and sides of the iPad, other than the side portions that fit within the curved tabs, are completely exposed when the cover is open. The front cover protects the face of the iPad when the cover is closed. A wide hand strap sewn onto the inside of the front cover allows for secure one handed viewing when the front lid is folded back and the reader’s hand is slid inside the hand strap.
The cover converts to a stand to hold the iPad at an angle for either typing or viewing. There are two separate grooves located one inch apart from each other on the inside front cover. To transform the cover into a stand, the bottom of the iPad is released from the two tabs securing it to the back cover and the back cover is folded at the scored center. The top of the iPad remains secured in the tabs on the back cover while the base of the iPad is nestled into one of the two grooves on the front cover. The grooves serve as a support for the iPad and allow the user to choose between two different viewing angles, a low angle for typing or a high angle for display.
The cover/stand is constructed of molded polycarbonate plastic that is covered on the exterior with cellular polyurethane plastic sheeting backed with plain woven textile fabric for mere reinforcement. The lining, which you describe as “micro suede,” is cellular sponge plastic sheeting backed with nonwoven textile fabric for mere reinforcement. Both the cellular polyurethane laminate on the exterior and the cellular sponge plastic lining material are considered to be of chapter 39 plastics for tariff purposes. There are also some cushioning layers of cellular foam plastic in between the shell and the lining in the front cover.
The sample is being returned as you requested. However, please note that the sample was cut during examination.
The applicable subheading for the C.E.O. Hybrid folding cover/stand for the iPad, product AHHB1P, will be 3926.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics…office or school supplies. The rate of duty will be 5.3 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Joan Mazzola at (646) 733-3023.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division