Ms. Sarah M. Nappi
Miller & Chevalier
655 Fifteenth Street, N.W., Suite 900
Washington, D.C. 20005-5701
RE: The tariff classification of assorted hooks from China and Taiwan.
Dear Ms. Nappi:
In your letter dated August 28, 2003, you requested a tariff classification ruling on behalf of The Stanley Works, located in New Britain, CT.
You have described your items as threaded, vinyl-coated, zinc-plated steel wire storage hooks of various shapes and sizes. All of these threaded items are designed to be attached to a wall or other surface in a specific manner for use in storing miscellaneous household articles such as tools, bicycles, lawn furniture, ladders, skis, pipes, plants and extension cords. The items for which you are requesting a classification decision are noted below:
Item # Description
¦ 132600 Overhead storage hook
¦ 132610 Ladder storage hook
¦ 132620 Tool storage hook
¦ 132630 Utility storage hook
¦ 132640 Hooks
¦ 756056 Wire coat and hat hook
¦ 758240 Mini coat hook (made of zinc)
¦ 758440 Mini coat hook (made of zinc)
¦ 758500 Shoulder hooks 15 ga (made of brass)
¦ 758520 Shoulder hooks 13 ga (made of brass)
¦ 758530 Shoulder hooks 11 ga (made of brass)
¦ 758540 Shoulder hooks 9 ga (made of brass)
¦ 751052 Bike hook
¦ 751089 Storage hook 20 piece pack
¦ 819260 Overhead storage hook
¦ 819270 Ladder storage hook
¦ 819280 Tool storage hook
¦ 819290 Utility storage hook
¦ 819300 All purpose storage hook
¦ 819305 Storage hook
¦ 819310 Rafter storage hook
¦ 819320 Coat & hat storage hook
¦ 822650 Rafter storage hook
¦ 827070 Steel hook
¦ 827080 Steel hook
¦ 827090 Steel hook
¦ 827100 Steel hook
¦ 827110 Steel hook
¦ 859270 Ladder storage hook
¦ 859280 Storage hook
The literature provided indicated that some of your items are made of brass or zinc, not steel. We have made note above of the materials other than steel. Your literature further indicates that all of the individual steel hooks are greater than 6mm in diameter except 819320. We are unable to make a determination pertaining to 756056, since no dimension pertaining to the diameter has been provided. In addition, there were no diameters or dimensional standards provided for the packages of hooks associated with 751089 and 819305. All of the steel hooks, with the exception of 132600, 756056, 751089, 819305 and 859280 are stated to have wood screw threading.
The applicable subheading for items 132600, 132610, 132630, 132640, 751052, 819260, 819270, 819290, 819300, 819310, 822650, 827070, 827080, 827100, 827110 and 859270 will be 7318.13.0060, 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: screw hooks and screw rings: having shanks or threads with a diameter of 6 mm or more. The duty rate will be 5.7% ad valorem.
The applicable subheading for items 132620, 756056, 758240, 758440, 819280, 819320, 827090 and 859280 will be 8302.50.0000, HTS, which provides for hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The rate of duty will be free.
The applicable subheading for items 758500, 758520, 758530 and 758540 will be 7415.33.8050, HTS, which provides for nails, tacks, drawing pins, staples (other than those of heading 8305) and similar articles, of copper or of iron or steel with heads of copper; screws bolts, nuts, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of copper: other threaded articles: screws, bolts and nuts: other screws and bolts; nuts: having shanks, threads or holes less than 6 mm in diameter. The rate of duty will be 3% ad valorem.
Your inquiry does not provide enough information for us to give a classification ruling for item numbers 751089 and 819305. Your request for a classification ruling should include the material, dimensions, design of each item along with a sample. When this information is available, you may wish to consider resubmission of your request. Your future ruling request submissions should “be limited to five (5) merchandise items” pursuant to 19 CFR 177.2.
Consideration was given to classifying all of your products in subheading 8302.50.0000, HTS, as you have suggested, however, that classification was deemed inappropriate. Those items were not fixtures similar to hat-racks, hat pegs and brackets. The provision for threaded fasteners more accurately defines the merchandise.
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 Kathy Campanelli at 646-733-3021.
Robert B. Swierupski