CLA-2-73:OT:RR:NC:N1:121
Jeffrey S. Grimson
Mowry & Grimson PLLC
5335 Wisconsin Avenue, NW. Suite 810
Washington DC 20015
RE: The tariff classification of a multipurpose construction screw kit from Taiwan
Dear Mr. Grimson:
In your letter dated January 23, 2020 you requested a tariff classification ruling on behalf of PrimeSource Building Products, Inc. This office has examined the sample and documentation you submitted.
The item under consideration is described as a multipurpose construction screw kit. The kit is comprised of 200 multipurpose screws, 2 T25 driver bits and 1 plastic handle, all packaged in a plastic, re-sealable, compartmentalized clamshell box. Each screw is made of carbon 1022 steel, partially threaded, has a Torx T25 star drive, bugle head with nibs, and a type-17 auger point. The screws are either green or tan, range in length from 1 ¼ to 3 ½ inches long, and are each less than 6 mm in diameter. You state the screws conform to the ASME B18.6.4 standard for tapping screws, have a minimum torsion strength of 52 pounds per inch, a point of 25 degrees (± 3 degrees) and predominate in the kit by value and weight. The screwdriver has a metal 4-inch shank, a handle made of polypropylene and thermoplastic rubber, and is compatible with the driver bits. The T25 star driver bits are made of S2 Alloy Steel. The case is made of polypropylene and polystyrene. These items will be imported in their full assembled form and marketed as a multipurpose construction screw kit for use in varying construction applications and appropriate for joining various materials.
The Explanatory Notes to the Harmonized Tariff System of the United States (HTSUS) provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3(b) provides that the term "goods put up in sets for retail sale" means goods that: (a) consist of at least two 2 different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. This office considers the subject multipurpose construction screw kit to be a set for tariff classification purposes. The screws, which perform the primary function of the kit and predominate by value and weight, impart the essential character to the set.
The applicable subheading for the multipurpose construction screw kit will be 7318.14.1060, HTSUS, which provides for Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Self-tapping screws: Having shanks or threads with a diameter of less than 6 mm: Other. The duty rate will be 6.2% 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 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