CLA-2-56:S:N:N6:351 805098
Mr. Robert Stankiewicz
Frank W. Winne and Son Inc.
44 North Front Street
Philadelphia, PA 19106
RE: The tariff classification of braided 8-strand, 720 foot long
mooring line (rope), 8 inches in diameter with 6-foot canvas
covered eyes (eye splices or loops) at either end, from
Korea.
Dear Mr. Stankiewicz:
In your letter dated December 12, 1994 you requested a
tariff classification ruling.
You have enclosed a photograph showing a braided 8-strand,
720 foot long mooring line (rope), 8 inches in diameter with
6-foot eyes at either end. The eyes appear to have been spliced
in a permanent manner and are covered with a canvas sheath. You
state that these ropes are imported specifically for mooring line
use only, and that the eyes will not be removed. You have also
enclosed letters from two of your customers, marine suppliers who
both state:
The rope is used for mooring large vessels to the dock,
the 720 foot lengths are required due to the fact that
most vessels are approximately 600 ft. in length and
covers the distance when mooring the vessel fore to aft
to stabilize it, leaving 120 feet slack to move with
the tides. Please also note the dock may be 50 feet or
so from the mooring kevel on the boat requiring extra
rope length.
As to the 6 foot canvas covered eye at each end of the
rope. This is needed to hook onto the dock kleat and
the kevel on the vessel. This 6 foot canvas covered eye
is never cut off.
The Explanatory Notes to the Harmonized Tariff Schedules
(HTS) constitute the official interpretation of the nomenclature
at the international level. The Explanatory Notes to heading 5609
indicate that this provision includes cordage cut to length and
looped at one or both ends. The mooring line at issue here is
looped in a substantial way at both ends. In addition, you have
provided evidence that it is cut to the length in which it will
actually be used to moor vessels.
The applicable subheading for the mooring lines will be
5609.00.3000, HTS, which provides for articles of...twine,
cordage, rope or cables, not elsewhere specified or included; of
man-made fibers. The rate of duty will be 9 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport