CLA-2-73:RR:NC:1:119 B84406

Mr. Michael A. Reilly
Prym-Dritz Corporation
P.O. Box 5028
Spartanburg, SC 29304

RE: The tariff classification of Common Pins from Malaysia

Dear Mr. Reilly:

In your letter dated April 10, 1997 you requested a tariff classification ruling.

The articles to be imported are dressmakers' or common pins of varying length, gauge and sharpness of points. Some have glass or plastic heads and some have a "T-bar" head (used in quilting). Some of the pins are made of brass but most are of stainless steel or nickel plated steel. The pins are used in various sewing or similar functions.

The Explanatory Notes to the Harmonized System at 73.19(B) state in part the following:

The pins of this group may have heads or other accessory parts of other base metals, glass, plastics, etc., provided that they do not become articles of an ornamental character and that they remain essentially iron or steel pins. The group includes: (1) safety pins; (2) ordinary pins.

The group also includes pointed shanks for brooches, badges (whether or not with swivel joints or connections), hatpins, etc.; pins and pointed shanks for fixing labels, mounting insects, etc.

The applicable subheading for the steel pins will be 7319.30.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for sewing needles... safety pins and other pins of iron or steel, not elsewhere specified or included... dressmakers' or common pins. The rate of duty will be 5.7 percent.

The applicable subheading for the brass pins will be 7415.10.0000, HTS, which provides for nail, tacks, drawing pins, staples (other than those of heading 8305) and similar articles of copper or of iron or steel with heads of copper... nails and tacks, drawing pins, staples and similar articles. The rate of duty will be 3.5 percent.

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 Jacques Preston at 212-466-5488.

Sincerely,

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