HQ 080501: Tariff classification of ski tow ropes

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                                      HQ 080501

                                    July 22, 1988


          CLA-2 CO:R:C:G 080501 JLJ

          CATEGORY: Classification

          TARIFF NO.: 735.06

          Ms. Patricia D. Ihnenfeld
          ERO Industries Inc.
          5940 W. Touhy Avenue
          Chicago, Illinois 60648

          RE: Tariff classification of ski tow ropes

          Dear Ms. Ihnenfeld:

               You asked our New York office for a tariff classification
          covering water ski tow ropes from Taiwan.  Your request was
          forwarded to this office for reply (New York reference number
          822489).  You submitted two samples along with your request.

          FACTS:

               You believe that both types of samples are classified under
          the provision for skis and ski equipment, all the foregoing and
          parts thereof, other, other, in item 735.06, Tariff Schedules of
          the United States (TSUS).

               The first ski tow rope sample is an orange colored rope
          sample consisting of two parts.  The first part is a blue handle
          consisting of a wood or aluminum cylinder covered with rubber or
          plastic.  The handle is attached to about five feet of rope with
          a loop on the end.  The second part consists of about 72 feet of
          braided cordage (i.e., rope) with loops at either end.  The rope
          in both parts is eight strand, braided polypropylene
          monofilaments without a core.

               The second sample is a multicolored ski tow rope with a
          handle portion which is similar to the first.  Instead of 72 feet
          of continuous rope, the second sample is composed of various
          lengths of rope, each with a loop at both ends.  The lengths
          range from 18 inches to 29 feet in length; they total 71 feet.

          ISSUE:

               Are the two tow ropes classified under the provision for
          skis and ski equipment in item 735.06, TSUS?













                                         -2-


          LAW AND ANALYSIS:

               The typical length for a water ski rope is approximately 75
          feet.  This is verified by both Encyclopedia Americana (1980
          edition) and Encyclopedia Brittanica, Micropaedia (1975 edition).
          Both samples with the handle and rope sections attached are
          approximately that length.  Both are items indispensable for the
          sport of water skiing.

               You state that the multicolored sample is to be used in
          water ski slalom competition.  You indicate that the rope is
          constructed in such a way that sections can be removed for each
          successive round of competition.

               The orange sample is specifically designed for use in water
          skiing in that it is the correct length and the rope is made with
          loops to attach it to the handle and to the boat.

               We note that ropes cut to a specific length for use in a
          sport have previously been classified as sports equipment.  In
          Customs Headquarters Ruling Letter (HRL) 054988 PR of June 21,
          1978, this office classified braided nylon rope in 120, 150 and
          165 foot lengths specifically designed and sold for use in
          mountain climbing as sporting equipment in item 735.20, TSUS,
          rather than as other articles of textile material, not specially
          provided for, in item 389.62, TSUS.

               The instant merchandise is similar in that both samples are
          ski tow ropes which function to pull water skiers behind boats.
          We presume that the samples are imported and used as units.

               Both samples appear to be dedicated to the sport of water
          skiing.  The parts are packaged together, sold together, and are
          necessary for water skiing.  The joining of the parts creates a
          new article of commerce -- water ski tow ropes.

          HOLDING:

               The instant samples are water ski tow ropes which are
          classified under the provision for other ski equipment in item
          735.06, TSUS, dutiable at the rate of 5.5 percent ad valorem.
          Products of Taiwan classified in item 735.06, TSUS, are eligible
          for duty free entry under the Generalized System of Preferences
          (GSP) if all requirements are met.

















                                         -3-


               Under the proposed Harmonized Tariff Schedule of the United
          States Annotated (HTSUSA), which is scheduled to replace the
          TSUS, the applicable provision is water skis, surf boards,
          sailboards and other water-sport equipment; parts and accessories
          thereof, other, in item 9506.29.00.40, HTSUSA, dutiable at the
          rate of 4.64 percent.  Products of Taiwan classified in this
          provision are not eligible for duty free entry under the HTSUSA.

                                          Sincerely,




                                          John Durant, Director
                                          Commercial Rulings Division














































          6cc:Area Dir., N.Y. Seaport
               (NIS-351)
          1cc:John Durant
          JLJohnson:tj:typed 06/22/88