CLA-2-83:OT:RR:NC:N1:121
Kathy Trotta
Conair Corporation
150 Milford Road
East Windsor, NJ 08520
RE: The tariff classification of travel padlocks from China
Dear Ms. Trotta:
In your letter dated September 17, 2019 you requested a tariff classification ruling. The samples you submitted have been examined and will be retained by this office for reference.
The merchandise in question is three “Travel Smart by Conair” base metal travel padlocks used to secure luggage.
The first padlock, described as the “Travel Sentry 3-Dial Inspection Status Lock” (item number TS390TS). This lock features a solid metal shackle, a rust resistant steel housing, and an inspection status indicator. It is 2.98 centimeters wide and has three numerical combination code dials, which are used by the traveler to lock and unlock the luggage. The Travel Sentry 3-Dial Inspection Status Lock also contains a cylinder lock located at the base, which opens with a specialized key used by a Transportation Security Administration (TSA) screener.
The second padlock, described as the “Travel Sentry Magnifying Padlock” (item number TS95LK). This lock is 3.53 centimeters wide, has a flexible metal wire shackle, and has three numerical combination code dials with magnified numbers for easy viewing. The Travel Sentry Magnifying Padlock contains a cylinder lock located at the base, which opens with a key used by a Transportation Security Administration (TSA) screener.
The third padlock, described as the “Travel Smart 3-Dial Cable Lock - Black” (item number TS399CL). This lock features a 1 ¾ inch flexible metal wire shackle, a rust resistant steel housing, and an inspection status indicator. It is 3.01 centimeters wide and has three numerical combination code dials, which are used by the traveler to lock and unlock the luggage. The Travel Smart 3-Dial Cable Lock - Black also contains a cylinder lock located at the base, which opens with a specialized key used by a Transportation Security Administration (TSA) screener.
The applicable subheading for the Travel Sentry 3-Dial Inspection Status Lock (item number TS390TS), the Travel Sentry Magnifying Padlock (item number TS95LK), and the Travel Smart 3-Dial Cable Lock - Black” (item number TS399CL) will be 8301.10.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Padlocks and locks (key, combination or electronically operated), of base metal… Padlocks: Of cylinder or pin tumbler construction: Not over 3.8 cm in width. The rate of duty will be 6.1 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8301.10.6000, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8301.10.6000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 https://hts.usitc.gov/current.
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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division