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Aug. 15 CBP Bulletin Revokes Rulings on Saddle Blankets, Vacuum Cleaner Parts

In the Aug. 15 issue of the U.S. Customs and Border Protection Bulletin (Vol. 46, No. 34), CBP published two notices of revocation and one notice of modification of rulings and treatment regarding the tariff classification of saddle blankets and vacuum hoses.

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Revocations Are Effective Oct. 15

CBP is revoking and modifying these rulings, as well as any treatment CBP previously accorded to substantially identical transactions, effective for merchandise entered or withdrawn from warehouse for consumption on or after Oct..

Saddle Blankets

Item: Certain handwoven saddle blankets measuring about 34 inches by 64 inches, to 34 inches by 68 inches.
New Ruling: HQ H161715 (dated 07/03/12) , revokes HQ 082167 (1990)
Old HTS/Rate: 6301, free to 11.4% (Blankets and traveling rugs)
New HTS/Rate: 4201.00.60, 2.5% (Saddlery and harness for any animal of any material)
Reason: It has been CBP's established position that saddle blankets of heading 4201 cannot exceed 30 by 62 inches unless it can be determined "with a reasonable degree of accuracy that merchandise exceeding those measurements is principally used as saddle blankets." CBP now notes that while saddle blankets may not exceed 30 by 62 inches very often in practice, no maximum size is articulated in the HTS or Explanatory Notes. Accordingly, CBP said its previous restriction of saddle blankets according to their size is unduly restrictive and therefore incorrect. CBP said the subject blankets are principally used as saddle blankets for animals as they (i) could act as padding between a horse and rider; (ii) are marketed in "saddle blankets' and "sports and outdoors" categories, (iii) have economic practicality for use as a saddle; among other reasons. Therefore, the subject saddle blankets are classified in heading 4201.

(See ITT's Online Archives 12021710 for summary of the proposed revocation of this ruling.)

Hose Assembly for Vacuum Cleaners

Item: Rubber and plastic hose assemblies for vacuum cleaners. The assembly includes a hose, a nylon brush and a connector and nozzle made of polypropylene. The flexible vacuum hose extends to clean hard to reach areas and it fits most standard vacuum cleaners.
New Rulings: HQ H024323 (dated 06/28/12), revokes HQ 735542 (1994). HQ H024320 (dated 06/28/12), modifies NY K85099 (2004)
Old HTS/Rate: 8509.90.15, 3.4% (rubber) 8509.90.1560 2% (plastic)
New HTS/Rate: 4009.12.00, Free, (Rubber) (Tubes, pipes and hoses, of vulcanized rubber other than hard rubber, with our without their fittings (for example, joints, elbows, flanges): Not reinforced or otherwise combined with other materials: With fittings.) 3917.33.00, 3.1% (Plastic) (Tubes, pipes and hoses and fittings therefore (for example, joints, elbows, flanges), of plastics: Other tubes, pipes and hoses: Other, not reinforced or otherwise combined with other materials, with fittings.)
Reason: Rubber: Even though rubber hose assembly is used solely with vacuum, classification is under specific named provision, and is for duty purposes considered Canadian. Origin for marking purposes is U.S. based on the hose portion of the assembly. Plastic: Plastic hose assembly considered a set under GRI 3(b) with hose providing essential character and classified is under specific named provision.

(See ITT's Online Archives 10062415 for summary of the proposed revocation of this ruling.)