The tariff classification of a plastic cable manager from China

N202255 February 23, 2012 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3926.90.9980 Ms. Tamra S. Parks Targus, Inc. 1211 N. Miller Street Anaheim, CA 92806 RE: The tariff classification of a plastic cable manager from China Dear Ms. Parks: In your letter dated January 30, 2012, you requested a tariff classification ruling. A photograph was provided with your letter. The cable manager, item #APK012US-50, is composed of thermoplastic urethane/silicone. It is circular and consists of two pieces connected together to a post in the middle. It is designed to organize cables and wires, which can be wrapped around the opening where the top and bottom pieces are connected. A suction cup on the bottom allows it to be securely attached to a desk, table top, computer or other flat surface. You identify the product as a laptop cable manager and suggest classification in subheading 8473.30.5100, Harmonized Tariff Schedule of the United States (HTSUS), as a part or accessory of a computer. However, the cable manager does not belong to a class of merchandise solely or principally used with computers or automatic data processing machines. The cable manager can be used to organize wires and cables for a broad range of products, such as phone chargers, electronic games and audio equipment. You refer to the urethane/silicone material used in the manufacture of the cable manager as “rubber.” Note 4 to Chapter 40, HTSUS, describes synthetic rubber as applying to unsaturated synthetic substances which can be irreversibly transformed by vulcanization with sulfur into non-thermoplastic substances which, at a temperature between 18 and 29 degrees Centigrade, will not break on being extended to three times their original length and will return, after being extended to twice their original length, within a period of 5 minutes, to a length not greater than 1-1/2 times their original length. Urethane and silicone are not unsaturated and not cross-linkable with sulfur, and thus do not meet the tariff definition of synthetic rubber. Both materials are considered to be plastics for tariff classification purposes. The applicable subheading for the cable manager, item #APK012US-50, will be 3926.90.9980, 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, (for) Thomas J. Russo Director National Commodity Specialist Division