CLA-2-82:RR:NC:1:115 B80844

Ms. Angela Tumbarello
Cyrk, Inc.
3 Pond Road
Gloucester, MA 01930

RE: The tariff classification of a tool kit keychain from China.

Dear Ms. Tumbarello:

In your letter dated January 3, 1997, you requested a tariff classification ruling. Your submitted sample will be returned to you as requested. The subject item is a tool kit keychain. This kit is comprised of 4 chrome vanadium screwdriver bits in a plastic housing, a steel key loop and a steel chain. The chain connects the housing to the loop.

Your merchandise is considered composite goods, consisting of different materials or made up of different components. This item shall be classified as if it consisted of the material or component which gives it its essential character. In this instance, the screwdriver bits impart the essential character.

The applicable subheading for the tool kit keychain will be 8207.90.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for interchangeable tools for handtools, whether or not power-operated, or for machine-tools: other interchangeable tools, and parts thereof: other: not suitable for cutting metal, and parts thereof: for handtools, and parts thereof. The duty rate will be 5.1% ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this 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 Melvyn Birnbaum at 212-466-5487.

Sincerely,

Robert B. Swierupski
Chief, Metals & Machinery Branch
National Commodity
Specialist Division