CLA-2-56:RR:NC:3:350 R00027

Dennis Heck
Yamaha Corporation of America
6600 Orangethorpe Avenue
P.O. Box 6600
Buena Park, CA 90622-6600

RE: The tariff classification of felt piano parts from Japan.

Dear Mr. Heck:

In your letter dated October 9, 2003, you requested a tariff classification ruling.

There were no samples or descriptive brochures submitted with your letter. A phone conversation with this office confirmed that the felt items are not impregnated, coated, covered or laminated. The letter listed the following four product descriptions: 1) T0491200 - Felt Front Bushing Cloth, 95% wool/5% nylon, not cut to size (9mm x 2000mm x 1.3mm), must be cut to desired length before it is installed on the piano

2) T5390140 - Felt Damper Flat, 100% wool, not cut to size (25mm x 370mm x 10mm), must be cut to desired length before it is installed on the piano

3) T5390120 - Felt Damper, 100% wool, not cut to size (10mm x 505mm x 10mm), must be cut to desired length before it is installed on the piano

4) T5901600 - Felt Pedal Rod Slide Cloth, 100% man made fiber, cut to size (40mm x 20mm x 1.8mm), to be installed on the piano in its imported condition

The applicable subheading for the T0491200 Felt Front Bushing Cloth, the T5390140 Felt Damper Flat, and the T5390120 Felt Damper will be 5602.21.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other felt, not impregnated, coated, covered or laminated: of wool or fine animal hair. The rate of duty will be 51.2 cents/kg plus 7.8 percent ad valorem.

The applicable subheading for the T5901600 Felt Pedal Rod Slide Cloth will be 9209.91.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories for pianos. The rate of duty will be 4.2 percent ad valorem.

This office concurs with your proposed classification regarding your part number T5901600. This office does not agree with your proposed classification in tariff subheading 5911.90.0080, HTS, of part numbers T0491200, T5390140, and T5390120. The textile products and articles of heading 5911, HTS, present particular characteristics which identify them as being for use in various types of machinery, apparatus, equipment or instruments or as tools or parts of tools.

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 Deborah Walsh at (646) 733-3044.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division