CLA-2-39:OT:RR:NC:SP:221
Ms. Nikki Wilson
Mallory Alexander International Logistics
1100 Temple Street
Little Rock, AR 72202
RE: The tariff classification of cable clips and cable grip clips from China.
Dear Ms. Wilson:
In your letter dated June 2, 2008, on behalf of Perfect 10 Antenna Co., you requested a tariff classification ruling.
Two bags of samples identified as cable/grip clips were provided with your letter. The clips are designed to secure cables or wires in an orderly fashion and mount them along walls or baseboard. The clips are packaged in quantities of 100 pieces per bag. Item #PVCCDBLK is a cable clip designed for use with a single cable. The clip is made of molded plastic in the shape of a “u” and has a pre-installed metal nail embedded in a channel next to the straight edge. The cable fits into the open area and the nail is secured into the wall to hold the cable in place. The nail is said to be suitable for wood, plaster, mortar or concrete. Item #GC12BLK is a grip clip designed for use with two single cables or a dual coaxial line. The clip is made of flexible molded plastic roughly in the shape of a “c” and has a pre-installed metal screw embedded in the top. The cables are inserted in the hollow portion of the clip and the screw is threaded from the top of the clip through a pre-formed hole at the bottom of the clip and then fastened to the wall. As you requested, the samples will be returned.
You suggest classification in heading 3924, Harmonized Tariff Schedule of the United States (HTSUS), which provides for household articles of plastics. The cable clips and the cable grip clips are not limited to household use, but are general purpose fittings that can be used in offices, factories and other locations as well as in homes. Legal Note 11 of chapter 39 defines builders’ ware of heading 3925 as applying to fittings and mountings intended for permanent installation in or on doors, windows, staircases, walls or other parts of buildings. The Explanatory Notes to the Harmonized Commodity Description and Coding System constitute the official interpretation of the HTSUS at the international level. The Explanatory Notes to heading 3924 exclude fittings and mountings designed for permanent attachment by means of screws, nails and adhesives from classification in heading 3924.
The applicable subheading for the cable clips, item #PVCCDBLK, and the cable grip clips, item #GC12BLK, will be 3925.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for builders’ ware of plastics, not elsewhere specified or included, 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 at 646-733-3023.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division