CLA-2-83:OT:RR:NC:N1:121
Ms. Silke Rees
Master Lock Company
P.O. Box 927
137 W. Forest Hill Avenue
Oak Creek, WI 53154
RE: The tariff classification of a padlock part from Mexico
Dear Ms. Rees:
In your letter dated February 22, 2010, you requested a tariff classification ruling. You submitted a sample that will be retained by this office.
The merchandise is identified as a Master Lock item 6121WO High Security Pro Series Lock Body and Shackle Assembly without a cylinder lock. It will be sold to the trade where users can customize them with their preferred cylinders. The body and shackle are made of steel and the body is covered with plastic. In your letter, you suggest classification under either subheading 8301.10.8000, Harmonized Tariff Schedule of the United States (HTSUS), as an unfinished padlock or 8301.60.0000, HTSUS, as parts of padlocks. It is our position that at importation, the lock body with shackle does not have the essential character of a padlock because it does not contain the cylinder lock. Therefore it would be classifiable as a part of a padlock.
The applicable subheading for the Master Lock item number 6121WO will be 8301.60.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for parts of padlocks and locks (key, combination or electrically operated), of base metal. The rate of duty will be 2.8 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 Barbara Kaiser at (646) 733-3024.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division