Ms. Sylvia Balev
Marc Jacobs Inc.
72 Spring Street, 9th floor
New York, NY 10012

RE: The tariff classification of a key ring from China

Dear Ms. Balev:

In your letter dated November 19, 2009, you requested a tariff classification ruling. The sample you submitted will be returned to you as requested.

The merchandise is item number M501127, a copper split wire ring connected to a zinc lobster clasp with an attached plastic mirror. The 2-inch high mirror is shaped like a giraffe and has a frame and back of plastic. According to information you provided, the predominant metal by weight of the article is zinc.

The applicable subheading for the key ring and lobster clasp with mirror will be 7907.00.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of zinc, other. The rate of duty will be 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

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 Ann Taub at (646) 733-3018.


Robert B. Swierupski
National Commodity Specialist Division