CLA-2-82:RR:NC:1:115 E85431

Mr. Arlen T. Epstein
Tompkins & Davidson
1515 Broadway
New York, N.Y. 10036-8901

RE: The tariff classification of Razor with retractable shaving blade from China.

Dear Mr. Epstein:

In your letter dated August 4, 1999 you requested a tariff classification ruling on behalf of your client Avon Products, Inc.

The sample submitted is described as a retractable shaving blade housed in a circular plastic cylinder. The cylinder measures approximately 3 inches in length with a diameter of 3/4 of an inch. The bottom end of the plastic cylinder features a twisting cap, which, when turned, causes a double bladed, replaceable razor blade to extend from the cylinder. The razor blade is retracted into the cylinder when the direction of the cap is reversed.

The sample will be returned as per your request.

The applicable subheading for the Razor with retractable blade will be 8212.10.0000, Harmonized Tariff Schedule of the United States (HAS), which provides for Razors and razor blades (including razor blade in strips) and base metal parts thereof. The rate of duty will be Free.

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 Melvyn Birnbaum at 212-637-7017.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division