The tariff classification of a Tie Down Strap from China

N152400 March 29, 2011 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9889 Ms. Barbara Kane Amsafe Commercial Products 22937 Gallatin Way Elkhart, IN 46514 RE: The tariff classification of a Tie Down Strap from China Dear Ms. Kane: In your letter received March 8, 2011, you requested a tariff classification ruling. You submitted a sample of Tie Down Strap part #73800000-03. It consists of two nylon textile straps. Each strap measures one inch across. The first strap is nine feet long; the second shorter piece is five feet long and has a metal spring clamp. Each strap has an S hook sewn onto one end. To use, the longer strap is inserted through the spring clamp mechanism and pulled through to the desired position. The pieces may be hooked together. The spring clamp is then used to securely tighten the strap into a non-slipping position. The applicable subheading for the Tie Down Strap part #73800000-03 will be 6307.90.9889, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem. You suggest the Tie Down Strap is classified in subheading 7318.15.2095, HTSUS, which provides for: Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other, other, at a free rate of duty. We do not agree. Because the spring clamp operated tie down possesses no threaded articles of iron or steel, it cannot be classifiable under heading 7318.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 the World Wide Web at http://www.usitc.gov/tata/hts/. Your sample will be returned. 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 Mitchel Bayer at (646) 733-3102. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division