CLA-2-63:OT:RR:NC:N3:351
Mr. Greg Fields
Vera Bradley Designs
12420 Stonebridge Road Roanoke, IN 46783
RE: The tariff classification of a textile lanyard keychain from Cambodia
Dear Mr. Fields:
In your letter dated April 3, 2024, but received on April 10, you requested a tariff classification ruling. This letter is part of a split ruling request. The other articles, item #29458-17867, the bag charms, and item #39737-18336, Heart Bag Charm, will be covered in New York Ruling N339413. The wide loop keychain will be addressed herein. A sample of the wide loop keychain was provided to this office and will be returned as requested.
The sample, item #36560-15441, described as a “Wide Loop Keychain,” is a textile lanyard keychain designed to be worn around the wrist or attached to a purse. The rectangular lanyard is composed of two layers of 100 percent cotton woven tartan plaid printed fabric sewn together. The lanyard measures 17 inches in length by 1 inch in width. One end of the lanyard is threaded through an iron split key ring and a swivel snap hook, folded over, and the ends are sewn together to secure the lanyard. The completed lanyard measures 9 ½ inches in length by 1 inch in width.
The lanyard keychain is a composite good consisting of a made up textile lanyard (heading 6307), a metal ring and dog clip (heading 7326). General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRI’s taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states that the heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings refer to part only of the items in a composite good, those headings are to be regarded as equally specific in relation to the goods, even if one of them gives a more complete or precise description of the good. As such, they are regarded as equally specific and classification of the composite good is to be determined by GRI 3(b) or GRI 3(c). GRI 3(b) states in part that composite goods, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. In this case, we find the essential character of the lanyard keychain to be the made up textile lanyard. The applicable subheading for the “Wide Loop Keychain” will be 6307.90.9891, HTSUS, which provides for “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” The rate of duty will be 7 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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Kristine Dodge at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division