CLA-2-84:RR:NC:1:115 C84567 `

Ms.Kimberly Fathauer
The A.W.Fenton Co.
1157 Rarig Avenue
Columbus, Ohio 43236-0614

RE: The tariff classification of a 75 pc. Power Ratcheting Bit & Socket Set from China

Dear Ms. Fathauer:

In your letter dated February 9,1998 on behalf of Consolidated Stores Corp. you requested a tariff classification ruling. The subject item is described as 75 pc. Power Ratcheting Bit & Socket Set, item number 205523, imported from China. The set consists of the following:

One ratcheting screwdriver, 50 bits, 10 metric sockets, 10 sae sockets, 2 plastic bit dispensers, and 1 durable plastic storage case. Both the bits and sockets are compatible with power drills and drivers, along with the ratcheting screwdriver sold in the set. In your inquiry you raise the question when is an item classified under HTS 8466 vs.Chapter 82. If the tool set has bits such as socket, ratcheting and screwdriver and can only be a working tool if it is inserted in a handle. Tool handle becomes an "interchangeable tool" or the tool handle can be looked at as that item that gives the tool set its "essential character". The bits are too small to be used without the handle. The above situation is a 8466 classification.

If the tool is made up of complete tools such as a screwdriver, wrench etc, each with its own handle, then the classification may fall under HTS 8205.90 or HTS 8206.00, depending on what type of tools are in the set. If the tool set is not considered a set than each item must be separately classified.

Item 205523 is made up that the handle is an "interchangeable tool" and is classified under HTS 8466.10.8075 at 4.1% ad valorem, as Tool Holders for any type of tool for working in the hand: Other.

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

The sample is being returned to your office, as you requested.

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
Director
National Commodity
Specialist Division