The tariff classification of a retractable web lanyard from Canada

NY L81381 December 17, 2004 CLA-2-84:RR:NC:1:104 L81381 CATEGORY: Classification TARIFF NO.: 8479.89.9897 Mr. Rodney Ralston UPS Supply Chain Solutions One UPS Way Champlain, NY 12919 RE: The tariff classification of a retractable web lanyard from Canada Dear Mr. Ralston: In your letter dated November 24, 2004 on behalf of North Safety Products Ltd of Ville D’Anjou, Quebec, Canada you requested a tariff classification ruling. In addition to the North Fall Protection catalog, you have provided a sample of the Self-Retracting Lifeline, style number FP0401. The sample is marked “North Single Retractable Lanyard Type 1”.You refer us to page 21 of the catalog which describes self-retracting lifelines including the retractable web lanyard at issue here. The catalog indicates that the lanyards will “lock up” in approximately 9 inches thereby limiting the overall exposure to a fall. These devices incorporate a breaking mechanism. The sample and catalog will be returned per your request. You state that the item is designed to be used by workers on scaffolds, tall buildings, water towers, etc. Once the Karabiner pin is hooked to an anchorage such as a scaffold railing, the worker can move the distance of six or eight feet (the length of the blue web cord) to perform his work. In the event of a fall, the orange webbing is designed to gradually give way thus breaking the fall to the total distance of the orange and blue webbing. This self-retracting (the lanyard retracts into the housing to keep it out of the way) lifeline is designed and sold solely as a safety device. It is not suitable for mountain or rock climbing. Style FP0401 is assembled in Canada from components originating in Japan, France, the U.S. and Canada. The retractable web lanyard unit is made in Japan and the Karabine captive pin (steel) in made in France. These two components account for 90% of the cost of the unit. The remaining components (orange webbing, etc.) originate in Canada or the United States. The applicable subheading for the Retractable Web Lanyard Style FP0401 will be 8479.89.9897, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter: other machines and mechanical appliances: other: other: other. The rate of duty will be 2.5 percent. 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 Robert Losche at 646-733-3011. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division