CLA-2-94:OT:RR:NC:N4:433
Christophe Beauregard
Customs Compliance Department
Richelieu Hardware Ltd.
7900 Henri-Bourassa Blvd. West
St-Laurent, QC H4S 1V4
Canada
RE: The tariff classification of a cam fastener from a variety of countries.
Dear Mr. Beauregard:
In your letter dated October 31, 2014, you requested a tariff classification ruling. As requested, the sample submitted will be returned to you.
The sample submitted is a cam fastener and dowel. The cam and dowel are entirely made of zinc. The shaft of the dowel is encased in plastic. The cam fits into a hole, usually in a wooden piece of furniture. The dowel also fits into a hole of a second piece of unassembled furniture that is placed perpendicular to the first piece. When the cam is tightened through a screwing action, it locks the dowel into place, thereby fastening the two pieces of furniture together. This product is used to fasten or bind parts of furniture together.
Your supplier suggests classification of the cam fastener and dowel in subheading 8302.42 of the Harmonized Tariff Schedule of the United States (HTSUS), which in pertinent part provides for “Base metal mountings, fittings, and similar articles suitable for furniture.” The cam fastener and dowel are used to join or affix two or more objects together. Headquarters ruling, HQ 950862 dated May 1, 1992, found that a cam fastener, tightened and released by torque, had the primary design characteristic of a screw. Consequently, screws are not considered to be mountings or fittings, and therefore do not fall under the purview of heading 8302, HTSUS.
You suggest classification in subheading 7907.00.6000 of the HTSUS. Heading 7907 of the HTSUS provides for “Other articles of zinc.” This heading covers a wide range of zinc articles that are not more specifically provided for elsewhere in the tariff schedule. However, we find that the zinc, cam fastener and dowel, not covered as a part for general use in the tariff schedule (see Section XV – Base Metals and Articles of Base Metal, Note 2) and not more specifically provided for elsewhere in the Nomenclature, to be classifiable in subheading 9403.90, HTSUS, the subheading covering parts of other furniture.
The applicable subheading for the zinc, cam fastener and dowel will be 9403.90.8041, HTSUS, which provides for “Other furniture and parts thereof: Parts: Other: Other: Other: Of metal: Other.” The rate of duty will be free.
You did not state the country of origin. The rate of duty provided above is the rate applicable when the merchandise is made in a country with which the United States has normal trade relations.
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 Neil H. Levy at E-Mail address: [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division