CLA-2-83:OT:RR:NC:1:102
Donna Riley
S & S Fastener Company
12120 Ellington Court
Cincinnati, OH 45249
RE: The tariff classification of a ball stud locking mechanism from China.
Dear Ms. Riley:
In your letter dated February 5, 2015 you requested a tariff classification ruling. A sample was included with your request and will be returned to you.
The product under consideration is a Ball Stud, Part Number 244478. You indicate in your submission that the Ball Stud is part of a latching mechanism for a casket lid and is made of steel. It is said, the Ball Stud is screwed into the lid of a casket and designed to be inserted into the latching mechanism in the base of the casket. The Ball Stud is inserted into the hole and the handle to the latch is slid over the Ball Stud in order to secure the casket lid shut.
Merchandise is classifiable under the HTSUS in accordance with the General Rules of Interpretation (GRIs). GRI 1 states that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the Customs Cooperation Council's official interpretation of the Harmonized System (HS). While not legally binding on the contracting parties, and therefore not dispositive, the ENs provide a commentary on the scope of each heading of the HS and are thus useful in ascertaining the classification of merchandise under the system.
The ENs for heading 8302, HTSUS, specifically include catches (including ball spring catches), bolts, fasteners, latches, along with fittings, and similar articles for caskets or coffins. Under the authority of GRI 1, we find the Ball Stud is specifically provided for in heading 8302, HTSUS, and the applicable subheading for the Ball Stud, Part Number 244478, will be will be 8302.49.6085, Harmonized Tariff Schedule of the United States (HTS), which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like, other mountings, fittings and similar articles, other, of iron or steel, of aluminum or of zinc, other, other. The rate of duty will be 5.7 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 Sandra Martinez at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division