CLA-2-66:RR:NC:3:353 D82819

Mr. Burton C. Berrettini
Penn Marketing Company, Inc.
P.O. Box 1267
Kingston, PA 18704-1267

RE: The tariff classification of a photographic umbrellas from China.

Dear Mr. Berrettini:

In your letter dated September 21, 1998, you requested a tariff classification ruling.

The submitted illustrated photographs and fabric swatch is that of photographic umbrellas. The umbrella appears to have eight ribs covered with a metallic fabric and a stick shaft. The umbrella is used with a high-intensity focusing lights, to avoid setting the focus on a fullspot or nearly full spot or fabric because they are likely to scorch.

The applicable subheading for the photographic umbrella will be 6601.99.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Umbrellas and sun umbrellas (including walking-stick umbrellas, umbrellas and similar umbrellas): Other: Other." The rate of duty will be 8.2% ad valorem.

There is no quota or visa on this product. Umbrellas may fall under the Federal Trade Commission Rules and Regulations, Under The Textile fiber Products Identification Act.

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 Kenneth Reidlinger at 212-466-5881.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division