CLA-2-82:S:N:N1:115 875212
Mr. Bruce Moore
Forrest Tool Company
P.O. Box 768
Mendocino, CA 95460
RE: The tariff classification of the "Max" Multipurpose Tool
from China.
Dear Mr. Moore:
In your letter dated May 13, 1992, you requested a tariff
classification ruling.
The subject item is designated as the "Max" Multipurpose
Tool. This tool is in fact a system of tools designed to perform
various functions. In its imported condition, the tool comprises
the following:
1. U.S.A. hickory handle axe assembled to an axe head
2. Shovel attachment
3. Straight pick attachment
4. Chisel pick attachment
5. Mattock attachment
6. Reversible rake/hoe attachment
All of the articles (except the hickory handle) above are
made of steel in China.
In addition, the following are also included in the boxed
tool:
a) A thumbscrew and bar tightener (country of origin China)
b) A leather axe sheath (country of origin U.S.A.)
c) A canvas bag for holding attachments (country of origin
U.S.A.)
The entire tool system is designed for use by such
agencies as the U.S. Department of Agriculture, the Department of
the Interior and the Army Corps of Engineers, etc. Several
possible uses of this tool include the planting of seedlings,
removing rocks, breaking up cement, digging wells, fighting forest
fires, etc. Each of the individual attachment tools is designed to
be attached to the axe head to create the second tool. The axe
handle becomes the handle for a shovel or pick, etc. Each of the
tool attachments is in effect an unassembled tool.
Your merchandise is considered composite goods, consisting
of different materials or made up of different components. This
item shall be classified as if it consisted of the material or
component which gives it its essential character. In this
instance, the essential character is imparted by the mattock,
pick attachments, rake and hoe, which are all classified under
the identical tariff classification. The U.S. made axe sheath
and the canvas bag are classified as American Goods Returned in
9801.00.1082 and are duty free. The "Max" tool set is packaged
in a sealed individual carton and sold as such to the end user.
The applicable subheading for the "Max" tool will be
8201.30.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for mattocks, picks, hoes and rakes, and
parts thereof... The duty rate will be 2.9% ad valorem.
This ruling is being issued under the provisions of
Section 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the
entry documents filed at the time this merchandise is imported.
If the documents have been filed without a copy, this ruling
should be brought to the attention of the Customs officer
handling the transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport