CLA-2-73:RR:NC:1:118 D83465

8481.80.1050; 8204.20.0000;
8204.11.0060; 8708.70.6060

Mr. Robert Glover
L.E. Coppersmith, Inc.
2041 Rosecrans Avenue, Third Floor
El Segundo, CA 90245

RE: The tariff classification of a Wheel Installation Kit from China.

Dear Mr. Glover:

In your letter dated October 7, 1998, you requested a tariff classification ruling, on behalf of Jenica, Inc., Ontario, CA. Your submitted sample will be returned to you as requested. The subject merchandise is described as follows:

The submitted sample, a Wheel Installation Kit part # PIK12-4A, is said to contain 16 lugnuts, 4 wheel locks, and 4 wheel valve stems. It is a complete kit for a consumer to lock a wheel onto a hub with an option to include hub cover locks and hub centric rings for vibration dampening. Optional Accessories:

a) Lug Sockets - designation #805, 1" in diameter and #352 for the locking lugnuts. b) Hub (Wheel) Cover Lock - which is a screw-like wheel locking item with a star- shaped head. c) 2-piece hand-operated Wrenching Tool - for tightening the hub cover lock. d) Hub Centric Ring - part #HCR-05, bore size 2.859", hub size 2.365". Except for the valve stems which are made primarily of copper and the ring which is made of plastic, the balance of the components are made of low carbon steel. The lugnuts are chrome-plated and the handtool is zinc-plated.

For the Wheel Installation Kit without the optional accessories of the Hub (Wheel) Cover Lock, Wrenching Tool and/or Hub Centric Ring, the following principle applies: When two or more goods are put up for retail sale and meet the criteria for sets, the goods are classified according to the component which gives them their essential character. In this instance, the lugnuts impart the essential character of the set. The non-locking lugnuts, which are the bulk of the items, sufficiently perform the function of holding the wheel in place.

For the Wheel Installation Kit with the optional accessories (with the exception of the Lug Sockets), the classification will be governed by GRI 1. As the Kit will not be treated as a set, each item will be classified separately.

The applicable subheading for the Wheel Installation Kit (without accessories it is a set) and for the non-locking chrome-plated Lugnuts when each item is separately classified will be 7318.16.0015, Harmonized Tariff Schedule of the United States (HTS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers, (including spring washers) and similar articles of iron or steel: threaded articles: lugnuts: non-locking chrome-plated. The duty rate will be free. Chrome-plated lugnuts from China are presently the subject of a dumping order. The case number is A-570-808. Should you require an Antidumping scope determination for this product, please file a request for a formal scope inquiry to: U.S. Department of Commerce, International Trade Administration, Office of Antidumping Compliance, IA Central Records Unit, Room B-009, Attention: Mr. Roland MacDonald, 14th Street and Constitution Avenue, N.W., Washington, DC 20230.

The applicable subheading for the 4 locking lugnuts (Wheel Locks) and the Hub Cover Locks will be 7318.16.0030, HTS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers, (including spring washers) and similar articles of iron or steel: threaded articles: lugnuts: locking. The duty rate will be free.

The applicable subheading for the 4 Hub Cover Locks will be 7318.15.8065, HTS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other screws: having shanks or threads with a diameter of 6 mm or more: other: other. The duty rate will be 8.7 % ad valorem.

The applicable subheading for the Valve Stems will be 8481.80.1050, HTS, which provides for hand operated valves, of copper. The duty rate will be 4.3% ad valorem. The applicable subheading for the Lug Socket will be 8204.20.0000, HTS, which provides for socket wrenches, with or without handles, drives and extensions, and parts thereof. The duty rate will be 9% ad valorem.

The applicable subheading for the Wrenching Tool will be 8204.11.0060, HTS, which provides for hand-operated spanners and wrenches, and parts thereof: nonadjustable, and parts thereof: other. The duty rate will be 9% ad valorem.

The applicable subheading for the Hub Centric Ring will be 8708.70.6060, HTS, which provides for road wheels and parts and accessories thereof: for other vehicles: parts and accessories: other. The duty rate will be 2.6% 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 Kathy Campanelli at 212-466-5492.

Sincerely,

Robert B. Swierupski
Director
National Commodity
Specialist
Division