CLA-2-73:OT:RR:NC:N1:113

Ms. Alice Liu
Atico International Inc.
P.O. Box 14368
Ft. Lauderdale, FL 33302

RE: The tariff classification of a keychain with a pill holder made in China

Dear Ms. Liu:

In your letter dated May 25, 2012, you requested a tariff classification ruling. The sample which you have submitted will be returned to you as requested.

The merchandise under consideration is identified in your letter as a keychain with a pill holder (Item A058EA00334). The article under consideration consists of an aluminum pill holder that is attached by a connector ring to a carabiner and a split wire ring. The connector ring, the carabiner and the split wire ring are made of iron. The cylindrical shaped pill holder measures approximately 20 mm in length by 50 mm in height and can hold multiple pills. The carabiner can be used to clip the subject article to a belt, a belt loop, a bag, a purse, etc. The split wire ring can be used to hold keys.

When classifying an article made of two different base metals, there is no determination of essential character. Principal weight is the sole determining factor. Section XV, Note 7, indicates that the classification of composite articles of base metal containing two or more base metals are to be treated as articles of the base metal predominating by weight over each of the other metals. The metal in the subject keychain with pill holder that predominates by weight is iron. Therefore, the article in question is classified in heading 7326, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel. The applicable subheading for the keychain with pill holder (Item A058EA00334) will be 7326.90.8588, HTSUS, which provides for other articles of iron or steel, other, other, 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 Ann Taub at (646) 733-3018.

Sincerely,

Thomas J. Russo
Director
National Commodity Specialist Division