The tariff classification of bridge accessory for cat play structure kits from China

N219496 June 14, 2012 CLA-2-44:OT:RR:NC:2:230 CATEGORY: Classification TARIFF NO.: 4421.90.9780 Mr. David King Solvit Products 1114 W. Harris Rd. Suite 101 Arlington, TX 76001 RE: The tariff classification of bridge accessory for cat play structure kits from China Dear Mr. King: In your letter, dated May 30, 2012, you requested a tariff classification ruling for a bridge accessory for cat play structure kits, or “cat trees”. Photos were submitted for our review. The bridge accessory measures approximately 30 1/4” long by 12” wide (at its widest point). The item consists of a woven polyester textile sleeve that encases plywood and hardboard (fiberboard) elements. A central plywood plank forms the walking surface of the bridge, while two curved, approximately trapezoidal pieces of hardboard on either end form the landings. Stitching holds the wood elements in place and allows the textile between them to function as flexible joints. Laid flat, the unit has the shape of a column or the letter “I”. At the corners of the unit are pieces of elastic that are anchored to construction elements of the cat trees. The accessory is designed to connect and allow passage between adjacent cat trees. The bridge accessory is made up of materials that are prima facie classifiable in different headings. As such, it is a composite good within the meaning of General Rule of Interpretation (GRI) 3(b). GRI 3(b) states that composite goods are to be classified according to the material or component that gives them their essential character. While the textile is functional, the essential character is imparted by the wood elements which form the structure of the bridge. Without the wood pieces, the unit would be unstable for use as a walking surface. The wood elements also predominate in weight and volume. The applicable subheading for the bridge accessories will be 4421.90.9780, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of wood: Other: Other: Other: Other. The rate of duty will be 3.3% 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 this ruling, contact National Import Specialist Laurel Duvall at (646) 733-3035. Sincerely, Thomas J. Russo Director National Commodity Specialist Division