CLA-2-83:OT:RR:NC:N1:121

Ms. Silke Rees
Customs Compliance Specialist II
Master Lock Company
PO Box 927
137 W. Forest Hill Avenue
Oak Creek, WI 53154

RE: The tariff classification of cable locks from China

Dear Ms. Rees:

In your letter dated September 22, 2009, you requested a tariff classification ruling. The submitted samples are being returned to you.

The merchandise under consideration is two cable locks. The body of each lock is made of base metal with a plastic outer housing.

Cable Lock 8119DPF is a combination lock with a 5 foot long cable made of vinyl coated, braided steel wire. It operates by rotating four numerical dials and allows for easy locking and handling with keyless convenience. It can be used to secure a variety of items, such as power equipment, ladders, trailers, tool boxes, bicycles and sports equipment. The width of the body measures 4.7 cm.

Cable Lock 8154DPF is a keyed lock with a 6 foot long cable made of vinyl coated, braided steel wire. It is imported with two keys that are connected with a metal split ring. The 5 pin cylinder locking mechanism offers maximum pick resistance. It can be used to secure a variety of items including toolboxes, ladders, gates, generators, hand trucks, bicycles, skateboards and sports equipment. The width of the body measures under 3.8 cm.

You state in your letter that you believe Cable Lock 8154DPF should be classified in subheading 8301.10.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for padlocks of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. This office, however, has determined that the width of the lock measures less than 3.8 cm.

The applicable subheading for the combination cable lock (Cable Lock 8119DPF) will be 8301.10.4000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated, of base metal…padlocks, not of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The rate of duty will be 3.8 percent ad valorem.

The applicable subheading for the key operated cable lock (Cable Lock 8154DPF) will be 8301.10.6000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated, of base metal…padlocks, of cylinder or pin tumbler construction, not over 3.8 cm in width. The rate of duty will be 6.1 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Barbara Kaiser at (646) 733-3024.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division