CLA-2-73:S:N:N1:103 891670
Ms. Barbara Klausman
James J. Boyle & Co.
7505 N.E. Ambassador Pl., Suite B
Portland, OR 97220
RE: The tariff classification of studded tire chain from Norway.
Dear Ms. Klausman:
In your letter dated October 15, 1993 on behalf of Quality Chain Company
you requested a clarification of a previous ruling, Ruling NY 875806 dated
July 10, 1992, concerning studded tire chain. This ruling classified studded
tire chain made in Norway in subheadings 7315.20.1000 or 7315.20.5000,
Harmonized Tariff Schedule of the United States (HTS), depending on the
diameter of the chain link. You have now asked whether studded tire chain
could be classified in the provision for stud link chain in subheading
7315.81.0000, HTS.
Studded tire chain and stud link chain are two totally different chains.
Studded tire chain is used to prevent vehicles from skidding. This type of
chain consists of links with a stud projecting outward from each link. The
stud digs into ice or snow and thus provides a vehicle with better traction.
Stud link chain is used in marine applications. Such chains consist of
an oval-shaped link with a cross-piece, referred to as a stud, across the
opening of each link for additional strength. Unlike studded tire chain, the
stud in stud link chain does not project out from the link but simply crosses
the link, thus forming a link shaped like the letter O with a bar across the
middle.
Studded tire chain is not composed of stud links as described above, and
thus studded tire chain cannot be classified in subheading 7315.81.0000, HTS.
Instead, studded tire chain is properly classifiable in the provision for skid
chain in subheadings 7315.20.1000 or 7315.20.5000, HTS, depending on diameter,
as indicated in Ruling Letter NY 875806 of July 10, 1992.
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