The tariff classification of reusable cases consisting of pallet bottoms, collars and lids from India and from Germany; box-pallets

NY A82482 May 9, 1996 CLA-2-44:RR:NC:GI:230 A82482 CATEGORY: Classification TARIFF NO.: 4415.20.8000 Mr. Donald Simpson BARTHCO International, Inc. 7575 Holstein Ave. Philadelphia, PA 19153 RE: The tariff classification of reusable cases consisting of pallet bottoms, collars and lids from India and from Germany; box-pallets Dear Mr. Simpson: In your letter dated March 18, 1996, on behalf of your client, SKF USA, Inc., you requested a tariff classification ruling. The ruling was requested on SKF reusable cases consisting of wooden bottoms, sides and lids. The bottoms are composed of several flat boards nailed together and measure one inch thick. Attached to the bottoms are feet extending 100 mm or approximately four inches down which facilitate the transport of the cases. The sides which are also known as collars consist of eight inch high wood sections with hinges and protrusions at the ends. Two or more collars may be attached together to form higher sides when assembling the cases. The sides may be collapsed or removed. The lids consist of plain flat boards or, according to literature submitted by you, they may consist of flat plywood with two narrow strips of wood attached to the top which aid in stacking. The lids are affixed to the cases by bands. The cases are typically used for the transport of ball and roller bearings. They are designed to be moved by the use of material handling equipment. The bottoms are pallets which are load boards designed essentially for handling by means of fork-lift trucks or pallet trucks. The cases are box-pallets which are pallets with a superstructure of at least three fixed, removable or collapsible vertical sides and designed for stacking. Photographs submitted by you show the cases stacked one on top of the other with spaces in between the feet allowing for easy handling. The primary feature of these cases is that they are designed for handling by means of fork-lift trucks or similar equipment. Added features such as costly sides or lids do not change the nature of these cases from being box-pallets. The applicable subheading for the SKF reusable cases will be 4415.20.8000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for other pallets, box-pallets and other load boards. The duty rate will be 14.3 percent ad valorem. Articles classifiable under subheading 4415.20.8000, HTSUSA, which are products of India are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations, if the GSP is renewed. 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 Paul Garretto at 212-466-5779. Sincerely, Roger J. Silvestri Director National Commodity Specialist Division