CLA-2-82:RR:NC:N1:118 L88705

Ms. Shira Wadro
Fiskars Brands, Inc.
2537 Daniels Street
Madison, WI 53718

RE: The tariff classification of an eyelet setter from China.

Dear Ms. Wadro:

In your letter, dated November 2, 2005, you requested a tariff classification ruling.

The “1/8” Eyelet Setter” is a combination paper punch and eyelet setter. The eyelet setter is comprised of two steel rods housed in a coiled spring. One end features a hollow steel paper punch that has been coated with a black oxide finish. The other end has a blunted steel tip designed to fit over, set in place, and hammer a metal eyelet. The eyelet setter measures 5” in length. It is utilized in paper crafting to punch uniform sized holes in paper and subsequently hammer an eyelet into the hole that has been made.

The applicable subheading for the eyelet setter will be 8205.59.5560, Harmonized Tariff Schedule of the United States (HTS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other: other: other: of iron or steel: other: other (including parts). The rate of duty will be 5.3% ad valorem.

Consideration was given to classification in subheadings 8203.40.6000, HTS, and 8205.51.3060, HTS, as you had suggested. However, since the punch portion of the eyelet setter does not describe the complete product and does not impart the essential character of this composite good, 8203.40.6000, HTS, would not apply. Inasmuch as the eyelet setter does not belong to the class or kind of articles principally used in the home, subheading 8205.51.3000, HTS, is also eliminated from consideration.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR).

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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division