CLA-2-90:OT:RR:NC:N1:105

Ms. Wynoka Harris
Skechers Footwear
228 Manhattan Beach Blvd.
Manhattan Beach, CA 90266

RE: The tariff classification of a Carabiner Compass from China.

Dear Ms. Harris:

In your letter dated December 8, 2008, you requested a tariff classification ruling. A sample was provided.

From the sample and our measurements, it weighs less than half an ounce, the compass face is 1 inch in diameter, and its maximum dimension is 2.5 inches in length. The carabiner has a swivel opening for it to attach to a belt loop, etc., but, given its light weight and small size, it would not likely be used to secure large or heavy objects. The compass arrow continues to point approximately north when the compass is turned on its axis.

It is similar to the carabineer compass in New York Ruling Letter N034298 – 118, 7-30-08.

We agree that the applicable subheading for this Carabiner Compass will be 9014.10.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "other", non-electrical, direction finding compasses. The rate of duty will be 2.9 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 J. Sheridan at 646-733-3012.


Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division