CLA-2-87:S:N:N1:101-857087
7326.90.9090
Mr. G. M. Stecko
Roll' Erg of the United States, Inc.
American Machine Bldg.
Manor Road
R.D. #6 Irwin, PA
RE: The tariff classification of Roll' Erg wheelbarrows from
France
Dear Mr. Stecko:
In your letter dated October 9, 1990 you requested a tariff
classification ruling regarding Roll' Erg wheelbarrows and
accessories. You have submitted descriptive literature.
The Roll' Erg wheelbarrows are specially designed hand
pushed vehicles that feature pneumatic wheels and a standard
frame (undercarriage) that supports various cargo bins. All
models have a multi-wheel system that can be adapted for hard
ground, construction work, sand and grass, or soft earth and mud.
The handles are adaptable (telescopic) to the size of the user
and are adjusted by a simple ratchet motion in seven positions.
Depending on its use, the vehicle may use two wheels or four
wheels. The specific models you plan to import are:
# 851, garden model with standard bin. Weight is 22 kgs.
# 1501, garden model with large bin. Weight is 33.6 kgs.
# 8113/B, garden model with metal plate and wood sides.
Weight is 31.5 kgs.
# 8114 EDCB, farmers model with pipe frame and optional
wood sides. Weight is 32 kgs.
The specific accessories you plan to import are:
#8100 B, automatic spade (perrette). This item is a non-
power hand operated spade made of steel. It features a
horizontal mounted pedal which the user steps on allowing the
tool to dig more easily into the earth. Weight is 6 kgs.
#8100 F, automatic fork (perrette). This item is a non-
power hand operated fork made of steel. It has the same features
as the automatic spade. Weight is 6 kgs.
#9100 T, attachment for tractor. This item is a steel tow
bar that is attached to the undercarriage of the Roll' Erg
wheelbarrow. It may be connected to a tractor, other vehicle or
bicycle for towing of the wheelbarrow. Weight is 1.9 kgs.
#8618 ABC, poly bag that fits on the bin for extra
capacity.
The applicable subheading for the Roll' Erg wheelbarrows
(models 851, 1501, 8113/B and 8114 EDCB) will be 8716.80.5050,
Harmonized Tariff Schedule of the United States (HTS), which
provides for other vehicles, not mechanically propelled. The
rate of duty will be 3.2 percent ad valorem.
The applicable subheading for the #8100 B automatic spade
(perrette) will be 8201.10.0000, HTS, which provides for
handtools of base metal, spades and shovels. The rate of duty
will be 3 percent ad valorem.
The applicable subheading for the #8100 F automatic fork
(perrette) will be 8201.20.0000, HTS, which provides for
handtools of base metal, forks. The rate of duty will be 2.8
percent ad valorem.
The applicable subheading for the #9100 T tow attachment
will be 7326.90.9090, HTS, which provides for other articles of
iron or steel. The rate of duty will be 5.7 percent ad valorem.
Your inquiry does not provide enough information for us to
give a classification ruling on #8618 ABC, poly bag. Your request
for a classif- ication ruling should include a sample of the bag
and the identity of the materials used to make the bag.
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