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The sprayer components are incorporated into all three segments of the Wet Jet unit to form a complete hand-operated spraying appliance. ISSUE: What is the classification under the HTSUS of the Swiffer Wet Jet™? The appliances of this heading are of two groups (see Chapter Note 3): (A) A limited class of articles classified here irrespective of their weight.... (B) A non-limited class of articles classified in this heading provided their weight is 20 kg or less.

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Sandler, Travis & Rosenberg LLC. Bade: This is in reply to your letter of January 2, 2002, to the National Commodity Specialist Division, New York, on behalf of The Procter & Gamble Manufacturing Company ("Procter & Gamble"), requesting a ruling with respect to the classification, under the Harmonized Tariff Schedule of the United States ("HTSUS"), of the Swiffer Wet Jet™ ("Swiffer Wet Jet" or "Wet Jet"). 00, HTSUS, as an other appliance. You assert that headings 8424 and 9603, HTSUS, are equally specific and classification is not resolved at GRI 3(a). The Harmonized Commodity Description and Coding System Explanatory Notes ("EN's") constitute the official interpretation of the Harmonized System at the international level. The three pieces snap together for ease of assembly by the ultimate consumer... [T]he liquid soap and cleaning cloths are not imported, but packaged together with the unit in the United States. Commercial Rulings Division. Without the thick absorbent cleaning pad, the hard plastic surface and Velcro strips would scratch the floor surface. When goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration.

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GRI 3 provides as follows: When, by application of rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: The heading which provides the most specific description shall be preferred to headings providing a more general description. HOLDING: At GRI 1 and GRI 2(a), the Swiffer Wet Jet™ is classified in subheading 8509. Accordingly, at GRI 1 and at GRI 2(a) (because the Wet Jet is imported unassembled), we find that the Wet Jet is described only by heading 8509, HTSUS. Your alternative claim is that the Wet Jet is classified in subheading 9603. Triple-layer pads trap and absorb dirt off your hard floors. The Wet Jet is imported unassembled in three basic pieces: the bottom section consists of the cleaning head with the sprayer nozzle mounted on top, an attached cartridge housing for the liquid soap, a battery-operated motor and the fluid-delivery system which includes a positive displacement gear pump; the middle pole section contains the electrical wiring; and the top pole section has the handle, the push-button for the sprayer and the electrical wiring... 09 acts to confirm that the Wet Jet is described in heading 8509, HTSUS, in that it provides that heading 8509, HTSUS, "covers a number of domestic appliances in which an electric motor is incorporated. " GRI 2(a) provides as follows: Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. FACTS: The goods are described as follows in your letter: The Swiffer Wet Jet™ ("Wet Jet") is a manual floor-cleaning tool with an internal hand-operated sprayer for wet cleaning hard surface floors. LAW AND ANALYSIS: Classification under the HTSUS is made in accordance with the General Rules of Interpretation ("GRI's"). The Wet Jet meets the terms of the heading text of heading 8509, HTSUS, and is fully and specifically described therein. RE: Swiffer Wet Jet™.

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While neither legally binding nor dispositive, the EN's provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. 8509 Electromechanical domestic appliances, with self-contained electric motor; parts thereof: 8509. The Wet Jet is electromechanical; it is a domestic appliance; it has a self-contained electric motor; and it weighs less than 20 kilograms (see Chapter 85, Note 3 and EN 85. You state that heading 8509, HTSUS, is not specific to the Wet Jet because the Wet Jet is not powered by the electric motor.

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There is no evidence to suggest or establish that the Wet Jet is a floor polisher. Therefore, you state that the Wet Jet is provided for in heading 8424, HTSUS. The HTSUS provisions under consideration are as follows: 8424 Mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not charged; spray guns and similar appliances; steam or sand blasting machines and similar jet projecting machines; parts thereof: Other appliances; 8424. The question remains whether the Wet Jet is classified in subheading 8509. 00 Other appliances. It shall also include a reference to that article incomplete or finished (or failing to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled. Sincerely, Myles B. Harmon, Acting Director. 1 Home Improvement Retailer. It is important to note that the motor is only a part of the sprayer unit and does not motorize the cleaning head; the unit is still manually propelled. Please enable JavaScript on your browser to proceed. 90, excerpted above).

GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. It is an electromechanical domestic appliance which has a self-contained electric motor. The Wet Jet does not meet the terms of heading 9603, HTSUS, in that it is not a broom, brush, non-motorized floor sweeper, or any of the other goods enumerated in that heading. Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. 24 does not support classification in heading 8424, HTSUS, in that the Wet Jet is not similar to the articles described in the EN.

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