CLA-2-74:OT:RR:NC:N1:113
Mr. Daniel J. Watson
Magna Donnelly
3401 128th Avenue
Holland, MI 49424
RE: The tariff classification of copper clips from the United Kingdom
Dear Mr. Watson:
In your letter dated May 23, 2008, you requested a tariff classification ruling. Samples of the copper clips and three of the mirrors that you use the clips on were submitted for our review.
The merchandise is identified as beryllium copper electric clips (part number 602536). The clips are imported on rolls of 3,000 feet per roll. The thickness of the electric clip is 0.17 millimeters (mm) and the width varies between 1.7 mm and 2.5 mm. The clips are shaped to fit on the edge of glass mirrors for automobiles. The function of the clip is to allow the attachment of a wire harness onto the edge of a glass mirror. The wire harness is then attached to the automobile electronics. You indicate in your letter that the copper clips are not insulated and do not incorporate any electrical or mechanical components.
You suggest that the copper clips should be classified as copper strip in heading 7409, Harmonized Tariff Schedule of the United States (HTSUS), which provides for copper plates, sheets and strip, of a thickness exceeding 0.15 mm. However, the copper clip is not a flat rolled product as defined in Chapter 74 Note
1 (g). Since the copper clips do not meet the Chapter 74 Note 1 (g) definition of strip, the clips are not classifiable as strip of heading 7409, HTSUS.
The applicable subheading for the copper clips will be 7419.99.5050, HTSUS, which provides for other articles of copper, other, other, other, other, other. The rate of duty will be free.
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 Ann Taub at 646-733-3018.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division