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

Ms. Sheri G. Lawson, LCB/CCS
Senior Regulatory Analyst
Client Transition and Compliance Services, U.S.
Willson International, Inc.
160 Wales Avenue, Suite #100
Tonawanda, NY 14150

RE: The tariff classification of wire insert holders, USB hubs, hinge pins, lids and bottoms for Tech Tubs from China

Dear Ms. Lawson:

In your letter dated February 3, 2014, on behalf of Copernicus Educational Products Inc., you requested a tariff classification ruling. Samples, specification sheets, drawings and advertising literature for the subject items were submitted with your ruling request. The samples will be returned as requested.

You stated in your letter that the items under consideration are for use in Tech Tub Bin TEC500 and Tech Tub Bin TEC57. The Tech Tub is a locking and re-charging solution designed to support electronic hand-hold devices such as tablets, iPads, and Chromebooks. The subject articles are identified as the TEC-AC5C – Tech Tub Chromebook 5 Device Insert, the TEC-AC7 – Tech Tub 7 Device Insert, Item 255141 – Belkin USB Hub, Part Number 23226 – Tech Tub Lid, Part Number 23227 – Tech Tub Bottom, and Part Number 31077 – Tech Tub Hinge Pin. Each item can be purchased separately. The items will be sold to distributors, schools and teaching facilities.

The TEC-AC5C – Tech Tub Chromebook 5 Device Insert is described as a rubber coated steel wire frame and foam tubing. It holds 5 devices including the larger tablets. The TEC-AC7 – Tech Tub 7 Device Insert is described as a rubber coated steel wire frame and foam tubing. It holds 7 devices. The wire insert holders are positioned inside and at the bottom of the bins. The TEC-AC5C and TEC-AC7 can only be purchased separately for use in the TEC57. From the information provided regarding Item 255141 (#B2B010 Belkin 7-port USB hub), the USB hub appears to be principally or solely used with an automatic data processing machine (ADP) machine and connects to the central processing unit (CPU) of an ADP machine.  It is used to effect interconnection of the CPU to input or output units.  The Part Number 23226 – Tech Tub Lid is made of ABS plastic. It is a replacement part for TEC500 and TEC57. The Part Number 23227 – Tech Tub Bottom is made of ABS plastic. It includes the lock hub (steel fixture where the lock for the tub goes through) and the hinge for the tub. It does not include the device inserts or other hardware. It is a replacement part for TEC500 and TEC57. The Part Number 31077 – Tech Tub Hinge Pin measures approximately 1/8 inch in diameter by 3 inches in length. It is made of steel wire and is not threaded. It connects the lid to the bottom of the tub and allows it to be opened and closed. It is a replacement part for the TEC500 and TEC57.

The applicable subheading for the TEC-AC5C – Tech Tub Chromebook 5 Device Insert, and the TEC-AC7 – Tech Tub 7 Device Insert will be 7326.20.0071, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for Item 255141 – Belkin USD Hub will be 8471.80.1000, HTSUS, which provides for automatic data processing machines and units thereof ...other units of automatic data processing machines, control or adapter units. The rate of duty will be free.

The applicable subheading for Part Number 23226 – Tech Tub Lid will be 3923.50.0000, HTSUS, which provides for stoppers, lids, caps and other closures, of plastics. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for Part Number 23227 – Tech Tub Bottom will be 3926.10.0000, HTSUS, which provides for other articles of plastics...office or school supplies. The rate of duty will be 5.3 percent ad valorem.

The applicable subheading for the Part Number 31077 – Tech Tub Hinge Pin will be 8302.10.6090, HTSUS, which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork…hinges, and parts thereof, of iron or steel, of aluminum or of zinc, other, other. The rate of duty will be 3.5 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,

Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division