CLA-2-90:OT:RR:NC:4:414

Ms. Becky Delsing
Best Buy
7601 Penn Ave. S.
Richfield, MN 55423

RE: The tariff classification of a lens cap with self-stick cap keeper from China

Dear Ms. Delsing:

In your letter dated June 21, 2010 you requested a tariff classification ruling.

Model # RF-LC58, Best Buy SKU #1071274, is the Rocketfish 58 millimeter (mm) lens cap. The lens cap is made of polycarbonate plastic and is designed to fit over the lens of a camera in order to protect the lens from dirt and scratches. The RF-LC58 is compatible with any digital single lens reflex (DSLR) or film single lens reflex (SLR) camera with a lens size of 58 mm. The lens cap is packaged together with a self-stick cap keeper which attaches securely to the lens. The cap keeper is made of woven nylon. It has an elastic leash which you can slide around the lens barrel and then it attaches to the cap with an adhesive tape.

You have suggested classification of the lens cap with cap keeper under subheading 9006.91.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts and accessories for cameras. However, the lens cap with cap keeper is more specifically provided for as an accessory for the lens, which is classified under heading 9002, Harmonized Tariff Schedule of the United States (HTSUS).

The lens cap and cap keeper, when packaged together for retail sale at the time of importation, are considered to be a set. General Rule of Interpretation 3 (b) of the Harmonized Tariff Schedule of the United States indicates that goods put up in sets for retail sale, shall be classified as if they consisted of the component which gives them their essential character. The essential character of the lens cap with cap keeper is the lens cap.

The applicable subheading for the lens cap with cap keeper will be 9002.11.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for objective lenses and parts and accessories thereof: for cameras, projectors or photographic enlargers or reducers: other: other. The rate of duty will be 2.3 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 Kiefer at (646) 733-3019.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division