CLA-2-42:OT:RR:NC:N4 441
Jacquelyn Votra
Trans-Border Global Freight Systems
2103 ROUTE 9 Round, NY 12151
RE: The tariff classification of four dog collars and one collar extender from Germany
Dear Ms. Votra:
In your letter dated July 20, 2023, you requested a tariff classification ruling on behalf of your client, Herm Sprenger Inc. You have submitted photographs and descriptions of five articles.
The five articles in question are described as 1) a middle link for lengthening (item number 50500 000 55), 2) collar, flat polished links (item number 50822 040 02), 3) collar, round links (item number 51112 045 65), 4) collar, long links (item number 51506 053 67), and 5) collar, medium, with assembly chain (item number 51545 050 57).
You have suggested that the dog collars and extender be classified in Heading 7315, Harmonized Tariff Schedule of the United States (HTSUS). Section Notes 2 and 2(a) to Section XV state “throughout the tariff schedule, the expression “parts of general use” means: articles of heading 7307, 7312, 7315, 7317, and 7318 and similar articles of other base metal, other than articles specially designed for use exclusively in implants in medical, surgical, dental or veterinary sciences (heading 9021).” As these articles, in their condition as imported, are complete specific identifiable articles and not parts of general use, they are precluded from classification in heading 7315, HTSUS.
The first article under consideration, item number 50500 000 55, is the collar extender. It is used to extend the length of a dog collar. Heading 4201 does not have a parts and accessories provision and, as such, this product is not eligible for classification within heading 4201.
Heading 7326 is a residual or basket provision which provides for other articles of iron or steel. Heading 7326 covers a wide range of iron or steel articles that are not more specifically provided for in any other heading in the HTSUS. The Explanatory Notes for heading 7326 state that “This heading covers all articles of iron or steel other than those covered by the preceding headings of this Chapter, or by Note 1 to Section XV, or articles specified or included in Chapter 82 or 83, or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel would only be classified under heading 7326, which covers other articles of iron or steel, if it is determined that the article is not more specifically provided for elsewhere in the tariff. As the collar extender is precluded from the other headings under consideration, heading 4201 and heading 7315, it shall be classified in heading 7326.
If the collar extender has no cross-sectional dimension of the wire which exceeds 16 mm, the applicable subheading will be 7326.20.0090, HTSUS, which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem.
If the collar extender has a cross-sectional dimension of the wire exceeds 16 mm, the applicable subheading will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other…other. The rate of duty will be 2.9 percent ad valorem.
The remaining articles are dog collars constructed of metal. They are fully functioning as dog collars in the condition in which they will be imported and shall be classified accordingly.
The applicable subheading for the complete dog collars will be 4201.00.3000, HTSUS, which provides for saddlery and harness for any animal (including traces, leads, knee pads, muzzles, saddle cloths, saddle bags, dog coats and the like), of any material: Dog leashes, collars, muzzles, harnesses and similar dog equipment. The rate of duty will be 2.4 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 at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Vikki Lazaro at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division