CLA-2 CO:R:C:G 082870 WAW

Mr. Leslie Alan Glick
Porter, Wright, Morris & Arthur
1233 20th Street, N.W.
Suite 400
Washington, D.C. 20036

RE: Brass lamp parts

Dear Mr. Glick:

This ruling is in response to your letter of September 27, 1988, requesting the classification of certain brass lamp parts under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).


The articles at issue are various solid brass lamp parts. The parts are designed for two different electric brass lantern styles, Products #233 and #320. Product #233 consists of thirteen different solid brass parts. The parts for Product #320 consist of sixteen different solid brass parts. The subject merchandise will be reimported into the United States after undergoing rough cutting, buffing, polishing and other operations required to prepare the parts for assembly into finished brass electric wall lamps in Mexico.


What is the proper classification of brass lamp parts under the HTSUSA?


The General Rules of Interpretation (GRI's) set forth the manner in which merchandise is to be classified under the HTSUSA. GRI 1 requires that classification be determined first according to the terms of the headings of the tariff and any relative section or chapter notes and, unless otherwise required, according to the remaining GRI's, taken in order.

Heading 9405, HTSUSA, covers lamps and lighting fittings including searchlights and spotlights and parts therof, not elsewhere specified or included. Under heading 9405, HTSUSA, there is a specific subheading which provides for lamp parts. More specifically, subheading 9405.99.2000, HTSUSA, covers lamp parts of brass. Since the instant lamp parts are of solid brass, and they are designed for use as parts of brass lamps, it is Customs position that they clearly fall within the purview of subheading 9405.99.2000, HTSUSA.


The brass lamp parts are classifiable under subheading 9405.99.2000, HTSUSA, which provides for parts of brass lamps and lighting fittings. The applicable rate of duty is 5.7 percent ad valorem.


John Durant, Director
Commercial Rulings Division