CLA-2-96:RR:NC:SP:221 F89297

Ms. Barbara Dawley
Meeks & Sheppard
1735 Post Road, Suite 4
Fairfield, Connecticut 06430

RE: The tariff classification of parts for pens from Japan.

Dear Ms. Dawley:

In your letter dated July 5, 2000, on behalf of Pilot Corporation, you requested a tariff classification ruling.

Samples were provided with your letter. The pen part consists of a metal ball attached to a plastic holder. The ball and holder are designed for direct insertion into the ink tube of a ball point pen. The applicable subheading for the metal ball with the plastic holder will be 9608.99.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of articles provided for in subheading 9608.10 (ball point pens), 9608.31 and 9608.39 (other than balls for ball point pens). The rate of duty will be free.

You have also requested a ruling on ink and grease. We are unable to issue a binding ruling on these products due to insufficient information regarding the composition, use and method of application for these products. For example, you have identified only one of the ingredients in the ink, and you have not identified the CAS numbers for the ingredients of the grease. You have not indicated where the grease will be used in the pen nor how it will function. If you wish to obtain a binding ruling on these products, please resubmit the samples with a detailed explanation of the use of each product and the composition percent by weight of all ingredients including Chemical Abstracts Service Numbers. 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 on the metal ball and plastic holder, contact National Import Specialist Joan Mazzola at 212-637-7034. If you have any questions regarding the information required for a ruling on the ink and grease, contact National Import Specialist Deborah Walsh at 212-637-7062.


Robert B. Swierupski
National Commodity
Specialist Division