CLA-2-82:S:N:N1:115 851173

Mr. Barry E. Powell
Grunfeld, Desiderio, Lebowitz & Silverman
707 Wilshire Blvd., Suite 5320
Los Angeles, CA 90017

RE: The tariff classification of a steel box cutter and blade from Taiwan or China.

Dear Mr. Powell:

In your letter dated April 2, 1990, on behalf of King Quality Co., Los Angeles, CA, you requested a tariff classification ruling. Your sample is being returned under separate cover as requested.

Your request for a classification ruling describes two items. Item No.1 comprises a rectangular 2 piece steel holder-handle and a single edge razor blade. One piece of the holder is designed for insertion of a single edge safety razor blade. A 45 degree cutout on the bottom in one corner of the holder permits the blade to be exposed and utilized for cutting. The other end of the holder is designed to be inserted and locked into the handle extension portion of the holder. This allows a sturdier grip of the unit. The single edge safety razor blade is of the class or kind of blade that fits into various types of holders that are designed to be used as scrapers that do not employ a cutting action. This rectangular blade includes a sharp edge on only one side. The side opposite the sharp edge has a steel covering that covers the whole side and permits handling of the blade in safe fashion. The blade is made of a thicker gauge of metal than that used in blades designed for shaving. When not in use, the handle with the blade may be reversed and inserted into the holder to shield the exposed blade. The second item is identical to the blade described above, but is described as being a replacement blade that is sold separately from the holder in retail packages of 100.

The applicable subheading for the combination holder and blade described as a box cutter as well as the replacement blade will be 8205.59.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for other edged hand tools of iron or steel as suggested in your inquiry. The rate of duty will be 5.3 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport