CLA-2-83:RR:NC:N1:121 L82253

Ms. Marsha L. Dawson
Graco Children’s Products Inc.
150 Oaklands Boulevard
Exton, PA 19341

RE: The tariff classification of a “Snugrider” stroller frame from China

Dear Ms. Dawson:

In your letter dated January 25, 2005 you requested a tariff classification ruling.

The merchandise is a frame that a car seat will snap into for easy mobility. The frame, called the Snugrider, consists of a folding stroller frame with wheels and a fabric utility storage basket. The Snugrider will be imported and sold separately, without the car seat.

In your letter, you request classification of this item under HTS 9401.20.00, the provision for seats of a kind used for motor vehicles. You claim that the item is not a stroller as it cannot be used without the car seat, since there is nowhere for a child to sit in this unit unless they are in a car seat. This item, however, is specifically described as an unfinished stroller and therefore is properly classified as a baby carriage under 8715.00.0020.

The applicable subheading for the Snugrider will be 8715.00.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for Baby carriages (including strollers) and parts thereof. The rate of duty will be 4.4% ad valorem. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Barbara Kaiser at 646-733-3024.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division