CLA-2-73:RR:NC:1:118 F85027

Mr. Peter A. Pennesi
V. Alexander & Co., Inc.
P.O. Box 30250
Memphis, TN 38130-0250

RE: The tariff classification of a household kit from China.

Dear Mr. Pennesi:

In your letter dated March 28, 2000, on behalf of your client, Bulldog Home Hardware Div. Newell, Memphis, TN, you requested a tariff classification ruling.

You have described your submitted sample, part number 7004210119, as a household kit. It contains 325 pieces and is further described as follows:

Picture hangers – 5 lb., 10 lb., 20 lb., 30 lb., 50 lb., 6’ picture wire, nails various sizes, picture hooks and small tooth picture hook, made of steel Machine screws – 6-32 x ¾”, 8-32 x ¾”, 10-32 x ¾”, made of steel Mug hooks – ½”, 7/8”, 1¼”, made of brass Washers – 5/16” flat, ¼” flat, ¼” lock, made of steel Machine nuts – 6-32 hex, 8-32 hex, 10-32 hex, made of steel Sheet metal screws – 10 x 1¼” pan head Phillips, 8 x 1” pan head Phillips, 6 x ½” pan head Phillips, #8 x 1¼” flat head, made of steel Hollow wall anchors – 1/8 x 2” toggle bolts, 1/8XS hollow wall anchors, #6 plastic anchors with screws, (except for plastic anchors) made of steel Nails, tacks & brads – 12 gauge x 2” wire brads, #17 1” wire nails, 13 gauge x 2” wire nails, thumb tacks, 1¼” 16 gauge wire brads, 1¼” 16 gauge wire nails made of steel. The nails and brads are zinc plated. The thumb tacks are nickel plated.

The picture hangers with all their components are considered a set with no essential character. Therefore, these items shall be classified by the subheading among those considering equal consideration, which comes last in the Tariff.

The applicable subheading for the picture hangers will be 7326.90.8585, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel: other: other: other: other: other. The duty rate will be 2.9% ad valorem.

The applicable subheading for the machine screws will be 7318.15.4000, 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 and bolts, whether or not with their nuts or washers: machine screws 9.5 mm or more in length and 3.2 mm or more in diameter (not including cap screws). The duty rate will be free.

The applicable subheading for the mug hooks will be 7415.32.9000, HTS, which provides for nails, tacks, drawing pins, staples (other than those of heading 8305) and similar articles of copper; screws, bolts, nuts, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles of copper: other threaded articles: other screws; bolts and nuts: other: having shanks, threads or holes less than 6 mm in diameter. The duty rate will be 3% ad valorem.

The applicable subheading for the flat washers will be 7318.22.0000, HTS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles, of iron or steel: non-threaded articles: other washers. The duty rate will be free.

The applicable subheading for the lock washers will be 7318.21.0030, HTS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles, of iron or steel: non-threaded articles: spring washers and other lock washers: helical spring lock washers. The duty rate will be 5.8% ad valorem.

The applicable subheading for the machine nuts will be 7318.16.0085, 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: nuts: other: other. The duty rate will be free.

The applicable subheading for the sheet metal screws will be 7318.14.1060, 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: self tapping screws: having shanks or threads with a diameter of less than 6 mm: other. The duty rate will be 6.2% ad valorem.

The applicable subheading for the toggle bolts and hollow wall anchors will be 7318.19.0000, HTS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles, of iron or steel: threaded articles: other. The duty rate will be 5.7% ad valorem.

The #6 plastic anchors with their screws are considered a set with no essential character. Therefore, these items shall be classified by the subheading among those considering equal consideration, which comes last in the Tariff.

The applicable subheading for the #6 plastic anchors with their screws will be 7318.14.1060, 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: self tapping screws: having shanks or threads with a diameter of less than 6 mm: other. The duty rate will be 6.2% ad valorem.

The applicable subheading for the nails and brads will be 7317.00.5530, HTS, which provides for nails, tacks, drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material, but excluding such articles with heads of copper: thumb tacks. The duty rate will be 0.2% ad valorem.

The applicable subheading for the thumb tacks will be 7317.00.1000, HTS, which provides for nails, tacks, drawing pins, corrugated nails, staples (other than those of heading 8305) and similar articles, of iron or steel, whether or not with heads of other material, but excluding such articles with heads of copper: other: of one piece construction: made of round wire: other: other: smooth shank: coated, plated or painted: galvanized. The duty rate will be 0.6% 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 212-637-7025.

Sincerely,

Robert B. Swierupski
Director
National Commodity
Specialist Division