CLA-2-83:OT:RR:NC:N1:121

Ms. Silke Reese
Customs Compliance Supervisor
Master Lock Company
P.O. Box 927
137 W. Forest Hill Avenue
Oak Creek, WI 53154

RE: The tariff classification of a trailer hitch receiver lock from China

Dear Ms. Reese:

In your letter dated August 16, 2011, you requested a tariff classification ruling. The submitted sample will be retained by this office.

The merchandise under consideration is described as a trailer hitch receiver lock, model number 2866DAT. It is chrome plated and has a swivel head, a hardened steel shackle, and two keys. The cylinder-shaped head measures 5.4 cm by 2.7 cm in diameter; it incorporates a brass, key operated, 4-pin tumbler lock cylinder, an aluminum cylinder case, and a water-tight plastic cap and seal. The shackle is a 13 cm long steel pin that measures 1.3 cm in diameter and has a 6.7 cm long removable sleeve. The lock measures 15 cm in length by 5.4 cm in width overall and is designed to fit a standard 2 inch trailer hitch receiver through a hitch ball mount. Your letter indicates that this lock is best used for “automotive and towing; trailers, vans and moving trucks; and marine recreation.” Internet research on eHow.com reveals that trailer hitch locks serve two purposes; they function as an added layer of attachment between motor vehicle and trailer and they prevent theft of the trailer when unhitched.

You propose classification of model 2866DAT in subheading 8301.20, Harmonized Tariff Schedule of the United States (HTSUS), which provides for locks of a kind used on motor vehicles. However, trailers are not classified as motor vehicles because they are not mechanically propelled. CBP has previously classified trailer locks as padlocks in subheading 8301.10, HTSUS.

The applicable subheading for the trailer hitch receiver lock will be 8301.10.8000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…padlocks, of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The rate of duty will be 4.8 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