CLA-2-83:OT:RR:NC:N1:121
Mr. William J. Polkinhorn
Bill Polkinhorn, Inc.
2401 Portico Boulevard
Calexico, CA 92231
RE: The tariff classification of a window shutter repair kit from Mexico
Dear Mr. Polkinhorn:
In your letter received on November 28, 2008, on behalf of Compro Sales Inc., you requested a tariff classification ruling. The sample which you submitted is being retained by this office.
The merchandise under consideration is described as a Window Shutter Repair Kit. It is used on a window shutter to replace broken hooks between the shutter slats and tilt rod. The hooks function to attach and connect the tilt rod to the slats so that the slats can be opened or closed by manipulation of the tilt rod. The kit consists of six finished units packed in a poly bag ready for retail sale. Each unit consists of two adhesive strips and two interlocking pieces of steel wire. One adhesive strip adheres to the surface of a wooden slat and the other strip adheres to the corresponding surface of the tilt rod. The wire piece is inserted through one side of each adhesive strip and is bent to secure it in place. Each wire piece is also interlocked with the other to form a connection between both adhesive strips.
You indicate that you believe the shutter repair kit should be classified in subheading 7317.00.6530, Harmonized Tariff Schedule of the United States (HTSUS), which covers nails, tacks, drawing pins, corrugated nails, staples and similar articles of iron or steel. However, products of heading 7317 are generally pointed and put in place with pressure with the intent of securing something. The formed and interlocked pieces of metal secured by tape are not esjudem generis with the exemplars of heading 7317.
The applicable subheading for the window shutter repair kit will be 8302.41.6080, HTSUS, which provides for base metal mountings, fittings and similar articles…other mountings, fittings and similar articles, and parts thereof, suitable for buildings, other, of iron or steel, of aluminum or of zinc, other. The rate of duty will be 3.9 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