CLA-2-82:RR:NC:1:118 I84758

Ms. Kim Young
BDP International, Inc.
2721 Walker Avenue N.W.
Grand Rapids, MI 49504

RE: The tariff classification of a minitools sidekick from China.

Dear Ms. Young:

In your letter dated July 26, 2002, you requested a tariff classification ruling on behalf of your client Meijer Distribution. The sample that you submitted with your request will be returned to you as requested.

You have described your sample as a minitools sidekick, style# 010439. It is a 3-piece key chain set consisting of 2 screwdrivers (1 Phillips and 1 flat) of carbon steel and 1 bottle opener of zinc alloy on a steel wire circular key ring.

The applicable subheading for the minitools sidekick will be 8205.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: sets of articles of two or more of the foregoing subheadings. The rate of duty is the rate of duty applicable to that article in the set subject to the highest rate of duty. In this instance, it is the carbon steel screwdrivers in subheading 8205.40.0000, HTS, which provides for screwdrivers, and parts thereof are the items in the set with the highest rate of duty. The rate of duty will be 6.2% 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 Kathy Campanelli at 646-733-3021.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division