CLA-2-76:RR:NC:N1:113 F86800

Mr. Peter A. Pennesi
V. Alexander & Co.
P.O. Box 30250
Memphis, TN 38130-0250

RE: The tariff classification of a Carabiner from China

Dear Mr. Pennesi:

In your letter dated May 3, 2000, on behalf of The Thermos Company, you requested a tariff classification ruling.

The sample you provided is called the Carabiner. The article is an aluminum D-shaped snap ring. After importation, it will be packaged with a leak-proof tumbler. The customer will use the Carabiner to clip the tumbler securely to a backpack or purse. The tumbler is designed with a hole for the Carabiner to slip through. The applicable subheading for the Carabiner will be 7616.99.5075, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of aluminum, other, other, other, other, other, articles of wire. The rate of duty will be 2.5 percent ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist James Smyth at 212-637-7008.

Sincerely,

Robert B. Swierupski
Director
National Commodity
Specialist Division