CLA-2-82:OT:RR:NC:1:118
Mr. Mike Choi
MKC Customs Brokers Int’l, Inc.
P.O. Box 91042
Los Angeles, CA 90009-1042
RE: The tariff classification of a razor blade from China.
Dear Mr. Choi:
In your letter dated October 23, 2009, you requested a tariff classification ruling on behalf of your client, Larson Design of Culver City, CA.
The imported item has been described as a steel razor blade. It is approximately 1½” long, measures ¼” from top to bottom, is 0.012” thick and is sharpened on one side. It has two holes along the upper half of the blade. After importation, the importer will insert the blade into a plastic casing and it will become a cutting knife having other than a fixed blade used for light cutting jobs.
The applicable subheading for the above referenced steel razor blade will be 8211.94.5000, Harmonized Tariff Schedules (HTS), which provides for knives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof: other: blades: other. The duty rate will be 1¢ each + 5.4% ad valorem.
Consideration was given to classifying these blades as an edged handtool, single edge razor blades other than for shaving, within subheading 8205.59.5505, HTSUS, as you suggested. As noted by the description, this provision provides for single edge razor blades that can be used in their imported condition as a hand tool. This type of razor blade would have a guard along the unsharpened edge to enable the user to safely hold the blade and work with it. The product that you have described is not designed or intended to be used in this manner.
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 Kathy Campanelli at (646) 733-3021.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division