CLA-2-89:S:N:N1:106-884524

Mr. Roger Barr
Premium Liferafts
60 Berry Street
Brooklyn, NY 11221

RE: The tariff classification of life rafts from England

Dear Mr. Barr:

In your letter dated March 30, 1993 you requested a tariff classif- ication ruling. You have submitted literature describing three life raft models.

The imported product is life rafts made from a light but strong multi-ply of butyl and polyamide. The rafts feature unitary construction design that removes the risk of separation between the two buoyancy chambers but at the same time continues to provide independent air compartments. The imported life rafts are intended solely for the purpose of emergency at sea (e.g., during a ship wreck). The rafts will be rented by pleasure boaters, sailors and non-commercial boaters.

Model no. LG3039/2 carries four persons, measures approximately 80 by 34 by 30 cm, and weighs approximately 20 kg.

Model no. LG3041/2 carries six persons, measures approximately 84 by 36 by 32 cm, and weighs approximately 26 kg.

Model no. LG3043/2 carries eight persons, measures approximately 85 by 38 by 34 cm, and weighs approximately 30 kg.

The rafts come in a soft valise stowage pouch and are manually launched. Each raft has a self contained inflation mechanism, comprising a bottle of carbon dioxide and a release cap actuated by pulling on a length of cord. This cord then becomes the tether line. The raft self inflates in approximately twenty seconds. Each raft contains a safety equipment which includes marine distress signals, a rubber patch and repair kit, a bailer, pump, sponges, and paddles to help move the raft away from the abandoned vessel.

The applicable subheading for the life rafts will be 8907.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for inflatable rafts. The rate of duty will be 3.8 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