CLA-2-39:OT:RR:E:NC:N4:421
Mr. Timothy Ruane
Illinois Tool Works Inc.
3600 W. Lake Avenue
Glenview, IL 60026
RE: The tariff classification of seals from the United Kingdom
Dear Mr. Ruane:
In your letter dated June 24, 2009, on behalf of ITW Fastex DBA ITW Envopak NA, you requested a tariff classification ruling.
Pictures of various types of security seals were included with your request. All of the seals are used to provide evidence of tampering. The Flexiseal™ is a one-piece indicative seal made of nylon plastic measuring approximately 7 ½ inches in length. The seal consists of a long thin saw-tooth type strip that loops back over itself and threads through a slot in the wide end of the seal by means of a ratcheting action. The top portion of the seal may be printed with logos or numbers. The seal cannot be removed without being broken, thus providing evidence of tampering. The Flexiseal is supplied in mats of ten strips connected together, in boxes of 1000 seals. It is used as an indicative seal in applications such as catering or airline trolleys, distribution or tote boxes, or ATM cassettes.
The Envotite™ is an indicative seal for use on fire extinguishers. It is constructed of polypropylene plastic and is similar in style to the Flexiseal. It is designed so that the narrow bead-like strip fits through the aperture on the fire extinguisher’s operating handle and then loops around and threads into a hole at the wide top end of the seal. The Envotite is supplied in mats of ten strips connected together, in boxes of 1000 seals. It is used as a seal that indicates if the extinguisher has been operated or tampered with.
The Gero™ and Solo™ comprise a two piece sealing system especially designed to fit in the recess of a catering trolley. The system is also suitable for use with air freight containers, roll cages and vehicle doors and is intended to be used where low cost and tamper evidence are key factors. The Gero component is a small reusable seal styled in the shape of a padlock. The Gero secures closed by means of the Solo, a single use plastic indicative seal component that is numbered for traceability. The Gero and Solo indicative seal components will sometimes be imported together. At other times the Gero and Solo components will be imported separately from each other.
The Envoflex™ is an aluminum bodied cable seal for use on freight containers, tankers, airline trolleys, vehicle doors and roll cages. It has a high strength aluminum outer body, zinc alloy inner body and galvanized steel locking mechanism. Envoflex seals are removable only with cable cutting tools and are not reusable. The non-preformed cable frays when cut to indicate tampering.
The Tenor™ and Trio™ is a base metal sealing system that combines both indicative and barrier security. The Tenor features interchangeable metal (Trio Metal) and plastic (Trio Plastic) hasps, which will be imported separately as spare parts. The Trio Metal hasps can only be removed with bolt croppers and are used on inbound airline flights to protect duty free goods. The Trio Plastic hasps are hand breakable and are used for general airline in-flight service carts.
The applicable subheading for the Flexiseal plastic indicative seals, the Envotite plastic indicative seals, the Gero/Solo sealing system, and the Gero padlock-shaped seal body will be 3923.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for stoppers, lids, caps and other closures, of plastics. The rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the Envoflex aluminum seals, the Tenor & Trio metal sealing system, and the separately imported Trio Metal hasps will be 8309.90.0000, HTSUS, which provides for stoppers, caps and lids (including crown corks, screw caps and pouring stoppers), capsules for bottles, threaded bungs, bung covers, seals and other packing accessories, and parts thereof, of base metal, other. The rate of duty will be 2.6 percent ad valorem.
The applicable subheading for the plastic Solo component, when imported separately from the Gero/Solo sealing system, and the separately imported Trio Plastic hasps will be 3926.90.9980, HTSUS, which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
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 Joan Mazzola (646) 733-3023.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division