CLA-2-63:RR:E:NC:N3:351
Mr. Kevin Ekstrand
Laufer Group International Ltd.
7007 NE Parvin Road
Kansas City, MO 64117
RE: The tariff classification of a textile tire chains and shoe traction devices from China
Dear Mr. Ekstrand:
In your letters dated March 3 and March 31, 2010, you requested a tariff classification ruling on behalf of your client, Cequent Consumer Products, of Solon, Ohio.
You submitted two samples. One is called the Easy Grip Composite Snow Chains and the other is called EZY Shoes. Both are made of knitted fabric made of cordage that you state is polyurethane and polyamide with an aramid core, with galvanized steel cleats.
The snow chains are made to be fitted over automobile tires for improved traction on ice- and snow-covered surfaces. They are held in place with webbed straps that extend from the center to the edges on the outer sidewall. Two are packaged with an instruction manual in a heavy-duty carrying bag.
The EZY Shoe is actually not a shoe, nor is it meant to be worn in place of shoes, as you acknowledge in your letter, but is worn over shoes for additional traction on ice- and snow-covered surfaces. It fastens across the top of the foot with hook-and-loop fastener strips. A pair will be imported in a disposable retail package.
The applicable subheading for the Easy Grip Composite Snow Chains with the carry bag and instructions, and the EZY Shoes will be 6307.90.9889, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem.
You suggest that the correct classification for the Easy Grip Composite Snow Chains is in subheading 8708.99.8160, which provides for cable traction devices for cars. However, this is an accessory for tires, not cars, and there is no provision for tire accessories.
The samples will be returned but one shoe device will be retained with the official case file.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
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 Mitchel Bayer at (646) 733-3102.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division