CLA-2-84:S:N:N1:103 893829

Mr. Richard Lee
DuBose Trading Company, Inc.
PO Box 819
906 Industrial Drive
Clinton, NC 28328

RE: The tariff classification of a Pallet Saver from China

Dear Mr. Lee:

In your letter dated January 10, 1994 you requested a tariff classification ruling.

The Pallet Saver is made of carbon steel in the shape of an inverted T, and is used to prevent damage to wood pallets. It attaches to the fork frame which moves up and down the mast of a fork-lift truck. In order to lift a palletized load, the forks of the fork-lift truck are normally positioned under the top deckboards of the pallet. These deckboards are made of relatively thin and narrow wood boards and thus can be damaged by the forks. The Pallet Saver is mounted to the fork frame between the regular forks. The base of the Pallet Saver comes into contact with the pallet's central wood stringer, made of thick lumber, which serves as the pallet's main brace. The Pallet Saver thus prevents the forks from making contact with, and possibly damaging, the deckboards. The applicable subheading for the Pallet Saver will be 8431.20.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts suitable for use solely or principally with the machinery of heading 8427 (fork-lift trucks). The rate of duty will be free.

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