The tariff classification of Golf Cart Components from China

NY L84555 May 13, 2005 CLA-2-87:RR:NC:MM:121 L84555 CATEGORY: Classification TARIFF NO.: 8716.80.5090 Mr. Jim Hunt E-Z Golf Cart 15373 Roosevelt Boulevard Suite 201 Clearwater, Florida 33760 RE: The tariff classification of Golf Cart Components from China Dear Mr. Hunt: In your letter dated April 22, 2005 you requested a tariff classification ruling. You submitted a photo and post card of the Golf Cart Components and the assembled Golf Carts. You state that five items are imported on one invoice and under one Bill of Lading: Main Frame (P/N 1001) – welded, bent and punched steel tubing and shafting. Axle (P/N 1002) – welded and bent steel tubing and shafting. Handle (P/N 1022) – bent and punched steel tubing, Brake Clamp (P/N 1301) – machined and welded steel tubing and shafting. Axle Extension (P/N 1302) – welded and punched steel tubing and shafting. All of these items are powder coated and some sections are zinc coated. You state that all of the items are components of golf pull or push carts that are assembled at E-Z Golf Cart in the United States with other components to make the finished product. The wheels, fasteners and hardware, plastic components, and packaging materials are obtained from domestic sources. The finished golf carts are sold to golf courses and are used as rental carts by these golf courses. You suggest that golf carts could have been classified under HTS 9506.39.000, dutiable at 4.9% ad valorem. We disagree as sub-heading 9506.31-39 includes golf clubs and other golf equipment, such as golf balls and golf tees. Golf Carts are excluded from Heading 9506. The applicable subheading for the Golf Cart Components (imported together), that have the essential character of a wheeled golf cart, will be 8716.80.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof; Other vehicles: Other…Other: Other. The rate of duty will be 3.2% ad 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 Barbara Kaiser at 646-733-3024. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division