CLA-2-73:OT:RR:NC:N1:121

Mr. Jerry Markowitz
Gittels Art Supply
5308 13th Avenue Ste 526
Brooklyn, NY 11219

RE: The tariff classification of steel nails and metal picture hangers from Germany

Dear Mr. Markowitz,

In your letter dated November 16, 2021, you requested a tariff classification ruling.

The first product under consideration is identified as “Picture Hanplartesger 10 Lb.” The brass plated hanger is 3/8 inches wide, ½ inch tall and ¼ inch in depth. It is used to hang a picture frame or artwork weighing up to 10 pounds.

The second product under consideration is identified as “Picture Hanger 20 Lb.” The brass plated hanger is 3/8 inches wide, 1 inch tall and ½ inch in depth. It is used to hang a picture frame or artwork weighing up to 20 pounds.

The third product under consideration is identified as “Picture Hanger 30 Lb.” The brass plated hanger is 3/8 inches wide, 1-1/8 inches tall and ½ inch in depth. It is used to hang a picture frame or artwork weighing up to 30 pounds.

The fourth product under consideration is identified as “Picture Hanger 50 Lb.” The brass plated hanger is 7/8 inches wide, 1-1/4 inches tall and ½ inch in depth. It is used to hang a picture frame or artwork weighing up to 50 pounds.

The fifth product under consideration is identified as a “Floreat Picture Nail”. The nail is 1 inch long, has a knurled head 1/8 of an inch in diameter and is made of steel. Per the photo provided, the nail is made of two-piece construction.

The applicable subheading for the Floreat Picture Nail will be 7317.00.7500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Nails of iron or steel, whether or not with heads of other material, but excluding such articles with heads of copper: Of two or more pieces. The rate of duty will be Free.

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.

We require additional information in order to classify the subject picture hangers described as Picture Hanplartesger 10 Lb. (item 1), Picture Hanger 20 Lb. (item 2), Picture Hanger 30 Lb. (item 3), and Picture Hanger 50 Lb. (item 4).  Please provide the following information for each item: Identify the type of metal (iron, steel, aluminum, etc.) that comprises each of the components from which the picture hangers are made.  If the picture hangers are composed of more than one metal, identify each metal and provide a breakdown by percentage by weight for each type of metal that comprises the hangers.

How are the picture hangers manufactured?  Provide all manufacturing steps.

If you decide to resubmit your request, please prepare a new letter, please reference the above noted NY ruling number and include all the material that we have returned to you and mail your request to Director, National Commodity Specialist Division, Regulations and Rulings, Office of Trade, 201 Varick Street, Suite 501, New York, New York 10014, Attn: Binding Ruling Request.  If your request was submitted electronically and the information required does not involve sending a sample, you can re-submit your request and the additional information electronically via the following link:  https://apps.cbp.gov/erulings/index.asp.

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