CLA-2-56:RR:NC:TP:350 817481

Mr. Stephen M. Zelman
Stephen M. Zelman & Associates
888 Seventh Avenue
New York, NY 10106

RE: The tariff classification of two needleloom felts for use in apparel, from Germany.

Dear Mr. Zelman:

In your letters dated December 11, 1995, on behalf of QST Industries, Inc., Chicago, IL, you requested a tariff classification ruling.

Two representative samples were submitted. The figures you supplied are believed to refer to the respective weights of the materials and not their values. The first item, identified in your correspondence as style Offitex OKL I, consists of a needleloom felt composed of a 65% wool/35% rayon man-made fiber blend. It has been manufactured by punching a sheet of textile staple fibers, without a textile base, with notched needles. The material measures about 1/16" in thickness and will be used as an "under collar" cloth for such garments as suits and sports jackets.

The second item, style Offitex E (or Offitex E L), consists of a needleloom felt which you state is composed overall (fiber and base) of a 50% wool/50% rayon man-made fiber blend. The material has been manufactured by needling a blend of 65%wool/35% rayon man-made fibers through a woven scrim composed of 100% rayon man-made fibers. This base scrim is completely hidden by the needled fibers. This material, which measures about 1/16" in thickness, will also be sold to garment manufacturers for use as "under collar" cloth for such garments as suits and sports jackets.

The applicable subheading for the first material (Offitex OKL I) will be 5602.10.9010, Harmonized Tariff Schedule of the United States (HTS), which provides for felt, whether or not impregnated, coated, covered or laminated, needleloom felt and stitch-bonded fiber fabrics, ... of wool or fine animal hair. The rate of duty is 12.3 percent ad valorem. Effective January 1, 1996, the duty rate will be 12.1 percent ad valorem.

The applicable subheading for the second material (Offitex E or Offitex E L), will be 5602.10.9090, HTS, which provides for felt, whether or not impregnated, coated, covered or laminated, needleloom felt and stitch-bonded fiber fabrics, ... of other than wool or fine animal hair. The duty rate is 12.3 percent ad valorem. Effective January 1, 1996, the duty rate will be 12.1 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 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 George Barth at 212-466-5884.

Sincerely,

Roger J. Silvestri
Director
National Commodity
Specialist Division