CLA-2-41:RR:NC:WA:353 B80506
Mr. Edward A. Igbinoba
United International Trading Supply Co.
1680 N.W. 195 Street
Miami, Florida 33169
RE: The tariff classification of cow, goat and sheep hides and skins from Nigeria, Benin,
Ghana and Niger
Dear Mr. Igbinoba:
In your letter dated December 14, 1996, received in our office on December 18, 1996
you requested a tariff classification ruling. A sample cow hide with hair was submitted for
examination.
The submitted sample is stated be representative also of goat and sheep hide and skins
you propose to import. You state that the imported hides are pretreated, pretanned and are
whole hides with the hair not yet removed.
The submitted cow hide sample with hair on was examined by our Customs laboratory
and it was determined that it had not been tanned and is therefore not considered leather for
customs purposes.
The applicable subheading for the cow hide if imported as a whole hide will be
4101.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for
"Raw hides and skins of bovine or equine animals (fresh, or salted, dried, limed, pickled or
otherwise preserved, but not tanned, parchment-dressed or further prepared), whether or not
dehaired or split: Whole hides and skins of bovine animals, of a weight per skin not exceeding
8 kg when simply dried, 10 kg when dry-salted, or 14 kg when fresh, wet-salted, or otherwise
prepared... or 4101.30.0000 HTS which provides for "Other hides and skins of bovine
animals, otherwise preserved.... Whole..". The rate of duty will be free.
The applicable subheading for a whole sheep hide will be 4102.10.0000 which provides for
"Raw skins of sheep or lambs (fresh, or salted, dried, limed, pickled or otherwise
preserved, but not tanned, parchment-dressed or further prepared), whether or not with wool
on or split, other than those excluded by note 1(c) to this chapter: With wool on." The rate of
duty will be free.
The applicable subheading for whole goat hides will be 4103.10.0000 which provides
for "Other raw hides and skins (fresh, or salted, dried, limed, pickled or otherwise preserved,
but not tanned, parchment-dressed or further prepared), whether or not dehaired or split, other
than those excluded by note 1(c) to this chapter. The rate of duty will be free.
Note 1(c) to Chapter 41 states: This chapter does not cover: Hides or skins with the
hair or wool on, raw, tanned or dressed (chapter 43); the following are, however, to be
classified in chapter 41, namely, raw hides and skins with the hair or wool on, of bovine
animals (including buffalo), of equine animals, of sheep or lambs (except Astrakhan,
Broadtail, Caracul, Persian or similar lambs, Indian, Chinese, Mongolian or Tibetan lambs),
of goats or kids (except Yemen, Mongolian or Tibetan goats or kids), of swine (including
peccary), of chamois, of gazelle, of reindeer, of elk, of deer, of roebucks or of dogs.
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 Martin Weiss at 212-466-5881.
Sincerely,
Paul K. Schwartz
Chief, Wearing Apparel Branch
National Commodity
Specialist Division