CLA-2-62:OT:RR:NC:N3:357
Ms. Mary Kastner
PMK International LLC
1107 SW Grady Way
Bldg B
STE 120
Renton, WA 98057
RE: The tariff classification of hunting vests, caps, self-adhesive patches, laser sensor, and scope mounting from Thailand
Dear Ms. Kastner:
In your letter dated July 17, 2014, you requested a tariff classification ruling on behalf of your client, Outdoor Products Inc. Your samples will be returned as requested.
Styles HSL010L and HSL011L are men’s hunting vest packages. Both packages include five additional self-adhesive IRISTM detectable patches. The vest is constructed from 100% polyester woven fabric and features a full front opening secured by a zipper closure, a V-neckline, on-seam zipper pockets, and a large rear pocket with a zipper closure. The vest has ten IRISTM detectable patches in the front and nine IRISTM detectable patches in the back. The self-adhesive IRISTM detectable patches are reflective patches consisting of pressure sensitive flat shapes of plastic sheeting with rounded corners that measure 6 ¼ inches by 3/8 inch.
Style HSL013L is a men’s hunting vest package with five additional self-adhesive IRISTM detectable patches, an IRISTM laser sensor, and a scope mount. The vest is constructed from 100% polyester woven fabric and features a camouflage design, a full front opening secured by a zipper closure, a V-neckline, on-seam zipper pockets, and a large rear pocket with a zipper closure. The vest has ten IRISTM detectable patches in the front and nine IRISTM detectable patches in the back. The self-adhesive IRISTM detectable patches are reflective patches consisting of pressure-sensitive flat shapes of plastic sheeting with rounded corners that measure 6¼ inches by 3/8 inch. The IRISTM laser sensor is a laser sensor that sends pulses of non-visible infrared laser light in the direction of fire. If the infrared laser light is reflected off the infrared reflective patches on a vest, the IRISTM laser sensor detects the laser light, signaling to the hunter that he or she has targeted another hunter. The scope mounting is used to mount the IRISTM laser sensor to the shotgun barrel or to a rifle scope.
Because styles HSL010L, HSL011L and HSL013L are not sets for tariff purposes, each item in each retail package must be separately classified.
You submitted a sample of two hats, which differ in color, but are identical in fabric content and construction. The baseball-style caps are constructed of 100% polyester knit fabric. The lined cap has six panels, a sweatband, a fabric covered button at the top of the crown and an adjustable strap at the back of the cap.
The applicable subheading for the hunting vests for styles HSL010L, HSL011L, and HSL013L will be 6211.33.0054, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Track suits, ski-suits and swimwear; other garments: Other garments, men’s or boys’: Of man-made fibers: Vests: Other. The rate of duty will be 16 percent ad valorem.
The applicable subheading for the self-adhesive IRISTM detectable patches will be 3919.90.5060, HTSUS, which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics, whether or not in rolls: other, other. The rate of duty will be 5.8 percent ad valorem.
The applicable subheading for the IRISTM laser sensor will be 9013.80.9000, HTSUS, which provides for Other optical appliances and instruments, not specified or included elsewhere in this chapter; Other devices, appliances and instruments: Other. The rate of duty will be 4.5 percent ad valorem.
The applicable subheading for the scope mounting will be 9013.90.9000, HTSUS, which provides for Other optical appliances and instruments, not specified or included elsewhere in this chapter; parts and accessories thereof: Parts and accessories: Other. The rate of duty will be 4.5 percent ad valorem.
The applicable subheading for the baseball-style caps will be 6505.00.6090, HTSUS, which provides for "Hats and other headgear, knitted or crocheted, or made up from lace, felt or other textile fabric...Other: Of man-made fibers: knitted or crocheted or made up from knitted or crocheted fabric: Not in part of braid, Other: Other: Other." The rate of duty will be 20 cents per kilogram plus 7 percent ad valorem.
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/.
At this time, we are unable to issue a ruling on the marking for styles HSL010L, HSL011L and HSL013L. We need additional information because it is unclear whether all of the products are manufactured in Thailand. If you decide to resubmit your request, please include all of the material that we have returned to you, and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section.
You also inquired as to the country of origin marking for the caps. Each cap has a sewn-in textile label that states, “Designed by Hunter Safety Lab in New Zealand, Reflective Film made in USA, Cap made in Thailand.” The proposed label would indicate the country of origin of the cap, preceded by the words "Made in" and will be in close proximity to and in at least the same size as the words “Designed by” and the phrase “Reflective Film made in U.S.A.” The proposed label, as described above, is conspicuously, legibly and permanently marked in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134 and is an acceptable country of origin marking for the imported caps.
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 Natalie Hanson via email at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division