CLA-2-93:OT:RR:E:NC:N2:235

Ms. Kimberly Jones
Harry F. Long Inc
608 Lambert Pointe
Hazelwood, Missouri 63042

RE: The tariff classification of Tipton Gun Vise from China

Dear Ms. Jones:

In your letter dated December 31, 2008 on behalf of American Dream Trading Company, you requested a tariff classification ruling.

The subject product, Tipton Gun Vise is stated to be specifically designed for the cleaning, maintenance or gunsmithing of a wide variety of firearms. The vise holds and supports the firearm in place while it is being worked on. It is configurable to handle bolt action rifles, break open shotguns, air-A5’s and handguns. A central aluminum channel allows the user to configure the vise to hold assorted firearms for a secure fit. You state that it is made of a high quality solvent resistant material. In your letter you indicate that you believe the classification of this product should be 9305.29.5000. This vise as stated in your letter will be used on pistols, rifles and airguns, therefore the subheading you suggest does not fully classify the product at hand.

The applicable subheading for the Tipton Gun Vise will be 9305.99.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts and accessories of articles of headings 9301 to 9304: Other: Other: Other." 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 Paul Hodgkiss at (646) 733-3046.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division