The tariff classification of a crocheted raffia hat from China

NY B88793 September 8, 1997 CLA-2-65:RR:NC:WA:353 B88793 CATEGORY: Classification TARIFF NO.: 6506.99.0000 Mr. Stephen S. Spraitzar George R. Tuttle Law Offices Three Embarcadero Center, Suite 1160 San Francisco, California 94111 RE: The tariff classification of a crocheted raffia hat from China Dear Mr. Spraitzar: In your letter dated August 18, 1997, you requested a tariff classification ruling on behalf of your client Dorfman. A sample of the hat, style L551, was submitted for examination. The submitted sample, style L551, a hat with a brim, is stated to be made from crocheted raffia. On the inside is sewn a fabric sweatband. A close examination of the raffia used in the construction of the hat revealed that the "yarns" are unspun raffia that are crocheted into a hat body and then blocked to form a brim. These "yarns" are not considered vegetable fiber yarns of headings 5306-5308 as these yarns must be spun and to be considered spun must have been 1.broken down into fine parallel fibers, commonly known as tow, rovings or silver; 2. carded, combed, or aligned in parallel fashion in some manner, and 3. caused to adhere to each other by means of spinning or twisting. The raffia used in the article at issue has not be subjected to this process. The raffia, if imported in the piece, would be considered a plaiting material of Chapter 46 and is not considered a textile material. The applicable subheading for the the raffia hat, style L551 will be 6506.99.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for " Other headgear, whether or not lined or trimmed: Other: Of other materials". The rate of duty will be 8.5 percent a valorem. 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, Textiles and Apparel Branch National Commodity Specialist Division