The tariff classification of the "Lift and Move System" from China

N087021 December 29, 2009 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3926.90.9980 Mr. Michael Skidmore Michael J. Skidmore, Customs Broker 103 Greenleaf Street Quincy, MA 02169 RE: The tariff classification of the “Lift and Move System” from China Dear Mr. Skidmore: In your letter dated December 1, 2009, on behalf of Potpourri Group Inc., you requested a tariff classification ruling. A sample was provided with your letter. The Lift and Move System is made up of four wheel rollers or trolleys and one roller lever. The system is designed to move heavy objects, such as appliances or furniture, across a room. The wheel rollers are molded from plastics and measure approximately 3 inches by 4 inches by 1 inch in height. There is a rotating circular non-slip cushion pad on the top surface on which the object to be moved can be placed. The bottom incorporates four plastic wheels on a metal axle. The roller lever consists of a steel lever with a steel swivel head, four plastic wheels and a plastic grip handle. The wheels on the lever act as a pivot between the lever and the floor to lift the object onto the wheel roller. Once the rollers are placed under the corners of the object, the object can be rolled or pushed to the desired location. As imported, the wheel rollers and the lever are considered to be goods put up in sets for retail sale, and are classifiable together in the tariff provision applicable to the component in the set that imparts the essential character. According to the cost breakdown provided with your letter, the value of the four wheel rollers is considerably greater than the value of the lever. In addition, the wheel rollers allow the heavy object to be moved. The lever provides a subsidiary role in lifting the object onto the wheel rollers. Therefore, the essential character of the set is imparted by the wheel rollers. As you requested, the sample will be returned. The applicable subheading for the Lift and Move System will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Joan Mazzola at (646) 733-3023. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division