CLA-2-74:RR:NC: 115 C89912

Ms Dianne Daniels

Handle-It Limited C89912

2515 Sonnington Drive

Dublin, OH 43016

RE: The tariff classification of a Grip Twist from Taiwan, Hong Kong and China.

Dear Ms. Daniels:

In your letter dated June 22, 1998, you requested a tariff classification.

The sample "Grip Twist" is made of Eva foam that fully covers a 12-gauge piece of solid copper wire. Each end of the Grip Twist is closed with a molded piece of plastic.

Your item is considered composite goods, consisting of different materials or made up of different components. These items shall be classified as if it consisted of the material or component which gives it its essential character. The copper wire imparts the essential character.

The applicable subheading for the Grip Twist will be 7419.99.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of copper: other: other. The rate of duty will be 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 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 Melvyn Birnbaum at 212-466-5487.

Sincerely,

Robert B. Swierupski

Director,

National Commodity

Specialist Division