CLA-2-96:RR:NC:SP:233 K80539

Ms. Grace Du
Annie International, Inc.
103A Park Drive
Montgomeryville, PA 18936-9613

RE: The tariff classification of hair grips/clips from China.

Dear Ms. Du:

In your letter dated November 5, 2003, you requested a tariff classification ruling.

The articles to be imported are hair grips/clips made of metal or plastic and metal with spring hinges, used for the purpose of holding individual sections or portions of hair. You have submitted the following samples:

Item nos. 3169,3171,3172,3191,3192,3193 are 4.5 cm in length Item nos. 3170,3195 are 9 cm in length Item no. 3175 is 12 cm in length Item no. 3185 is 10 cm in length

In your letter you suggest classification under 9615.90.3000, which provides for “Combs, hair-slides and the like: hairpins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516 and parts thereof: Other: Hair pins.” Although the hair grips/clips are used for the purpose of holding a specific portion of the user’s hair in a particular position, and may serve the same purpose as a hair pin, they do not meet the definition of a hair pin. The Random House Dictionary of the, English Language, Unabridged (1973), page 637, defines “hair pin” as 1. A slender U-shaped piece of wire, shell, etc. used by women to fasten up the hair or hold a headdress.” The hair grips/clips under consideration have spring hinges and are therefore properly classified under 9615.90.6000.

The applicable subheading for the hair-grips/clips will be 9615.90.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Combs, hair-slides and the like: hairpins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516, and parts thereof: Other: Other: Other.” The rate of duty will be 11% 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 Lawrence Mushinske at 646-733-3036.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division