The tariff classification of arm harnesses from United Kingdom

N319194 May 28, 2021 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9891; 9817.00.96 Ms. Laura Maclean Ramble Tag Ltd. 220 Anniesland Road Glasgow, United Kingdom RE: The tariff classification of arm harnesses from United Kingdom Dear Ms. Maclean: In your letter dated May 2, 2021, you requested a tariff classification ruling on behalf of your client, The Low Vision Shop. Samples were provided to this office and will be retained for training purposes. You state the “Metro Ramble Tag®,” is a contactless guidance aid designed to be worn on the upper arm of a guide to assist a disabled or blind person when walking. The arm harness is composed of two layers: an outer layer of 100 percent polyester dyed woven fabric coated with polyurethane; and an inner layer of non-slip rubber consisting of polyvinyl chloride, soybean oil, palm oil, and plasticizer-acetyltrivtylcitrate filler. The edges of the harness are finished with a black 100 percent polyester knitted binding. The harness attaches around the arm with two hook-and-loop fasteners on each end. In addition, the harness features a 5 ¾ inch long x 1 inch wide handle that is composed of two layers of fabric: a 100 percent polyester woven dyed webbing outer layer; and a 100 percent polyester knitted dyed fabric inner layer. The harness is available in one size measuring 12 ½ inches long x 5 ½ inches wide. The item number will be delineated by the color and the appropriate arm that the harness guide is worn on: MTOG2006 (orange, guide on right arm), MTOG2007 (orange, guide on left arm), MTBG2008 (black, guide on right arm), and MTBG2009 (black, guide on left arm). The harness is washable and reusable. You state the “Original Ramble Tag®,” is a contactless guidance aid designed to be worn on the arm of a guide to assist a disabled or blind person when walking. The arm harness is composed of two layers: an outer layer of 100 percent polyester dyed woven fabric coated with polyurethane; and an inner layer of non-slip rubber material consisting of polyvinyl chloride, soybean oil, palm oil, and plasticizer-acetyltrivtylcitrate filler. The edges of the harness are finished with a black 100 percent polyester knitted binding. The harness attaches around the arm with two hook-and-loop fasteners on each end. In addition, the harness features a 8 ½ inch long by 1 ¼ inch wide handle that is composed of three layers: a 100 percent polyester woven dyed webbing outer layer; a 100 percent polypropylene braided cord middle layer; and a 100 percent polyester knitted dyed fabric inner layer. The harness is available in three sizes: the small size measures 8 ¾ inches long x 5 ¾ inches wide; the regular size measures 12 ½ inches long x 5 ½ inches wide; and the XL size measures 14 inches long x 5 ¼ inches wide. The guide will wear the small size harness on the wrist and the regular and XL size harness on the upper arm. The item number will be delineated by the color and the appropriate arm that the harness guide is worn on: RTBG2002, (black, guide on left arm), RTBG2003, (black, guide on right arm), RTOG2005 (orange, guide on right arm), RTOG2004 (orange, guide on left arm), RT2004-CAMO-GOR (camouflage, guide on right arm), RT2004-CAMO-GOL (camouflage, guide on left arm), RT2004RD-GOR (red, guide on right arm), RT2004RD-GOL (red, guide on left arm), RT2004BL (blue, guide on right arm), RT2004BL-GOL (blue, guide on left arm), RT2004PK-GOR (pink, guide on right arm), and RT2004PK-GOL (pink, guide on left arm). The harness is washable and reusable. The applicable subheading for the “Metro Ramble Tag®” and the “Original Ramble Tag®” will be 6307.90.9891, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 percent ad valorem. In your ruling request, you suggested a secondary classification under subheading 9817.00.96, HTSUS, for the “Metro Ramble Tag®,” and the “Original Ramble Tag®” as articles specially designed or adapted for use by the chronically or permanently disabled or handicapped persons. HTSUS Chapter 98, Subchapter 17, U.S. Note 4(a), states that the term “blind or other physically or mentally handicapped persons” includes any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working. Both items are to be worn by a guide while walking with a disabled or blind person who holds onto the handle. Based on the information supplied, it is the opinion of this office that a secondary classification will apply for the “Metro Ramble Tag®,” and the “Original Ramble Tag®” under subheading 9817.00.96, HTSUS, as “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing article: Other.” The rate of duty is free. 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 https://hts.usitc.gov/current. 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 Kristine Dodge at kristine.dodge@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division