CLA-2-39:S:N:N3D:221 851405
Ms. M. Madeline Martinez
Danke International Ltd.
Park Avenue Atrium
237 Park Avenue, 21st Floor
New York, NY 10017
RE: The tariff classification of camping mats from Belgium, the
Netherlands, West Germany and South Korea.
Dear Ms. Martinez:
In your letter dated March 23, 1990, which was received in
this office on April 11, 1990, you requested a tariff
classification ruling.
Included in your letter was a catalog depicting a large
variety of mats. The mats illustrated in the first few pages
appear to be in the form of rectangular sheets which have not
been further processed such as by having the edges rounded,
hemmed or beveled. Some sheets are made entirely of foamed
polyurethane. Others are made entirely of foamed polyethylene.
Another group is made from a layer of foamed polyurethane
laminated to a layer of foamed polyethylene. For the purposes of
this reply, it is assumed that the "belts" which are described in
the literature are not sewn or attached to the mats, but are
separate components which are merely slipped over the rolled-up
mats in order to keep them from unrolling.
The applicable subheading for the mats in the form of
rectangular sheets which have not been further worked, when made
completely of polyurethane, or when bonded to polyethylene but in
chief weight of polyurethane, will be 3921.13.5000, Harmonized
Tariff Schedule of the United States (HTS), which provides for
other plates, sheets, film, foil and strip, of plastics,
cellular, of polyurethane, other. The rate of duty will be 4.2
percent ad valorem.
The applicable subheading for the mats in the form of
rectangular sheets which have not been further worked, when made
completely of foamed polyethylene, or when bonded to polyurethane
but in chief weight of the polyethylene, will be 3921.19.0000,
HTS, which provides for other plates, sheets, film, foil and
strip, of plastics, cellular, of other plastics. The rate of
duty will be 6.6 percent ad valorem.
The catalog illustrates other mats, including some made with
a layer of faomed plastics combined with an aluminum layer.
Other mats have rounded edges and have been combined with textile
materials. Some have included pillows. Three samples of camping
mats, not identified as to style number, were included with the
letter. These samples include textile, aluminum and plastic
components.
Your inquiry does not provide enough information for us to
give a classification ruling on the remaining articles. Your
request for a classification ruling should include a breakdown by
both weight and value for each component in the mats. For any
articles with a layer of aluminum, specify whether the aluminum
is in the form of a separate foil layer or whether it has been
vacuum coated onto a plastic film. In all cases, the cost and
weight of the aluminum should be shown separately from the cost
and weight of the material onto which it is coated. The cost of
all textile components should be shown separately. Each request
should be limited to no more than 5 items of the same class or
kind.
The samples submitted with your request are being returned.
If you wish a ruling on these products, please resubmit them,
identified as to style number, with the complete breakdowns
requested above. Describe how they are used, and especially
whether the openings are meant for the insertion of a cushion or
whether the user will fit himself into the opening and use the
top textile layer as a blanket.
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