CLA-2-82:OT:RR:NC:1:118

Mr. Sean Scarbrough
Taggart International, Ltd.
6603D Royal Street
Ste. B
Liberty, MO 64068

RE: The tariff classification of a multi-purpose tool and a caulk tube cutter from China.

Dear Mr. Scarbrough:

In your letter dated June 16, 2011, on behalf of Screwpop Tool, LLC, you requested a tariff classification ruling.

Your request for a ruling concerns two items. The first item is called a “Tricky Wrench™.” You state that it is used to adjust the wheels and other moving parts of a skateboard. This multi-purpose tool includes the following: two socket wrenches, bottle opener, socket driver and a removable self locking hexagonal key that incorporates an Allen wrench, knurling tool and Phillips screwdriver. It is designed to be carried on a key ring or carabiner.

You refer to the second item as “The Perfect Caulk Cutter™.” You state that it is used to cut the tips off of tubes of caulk or other material using similar dispensing mechanisms. The tool is made of hardened plastic that encases a guillotine-type metal blade. The tool works by retracting the blade, inserting the tip of the tube of caulk into the guide and pressing the blade forward. The tool has a key ring attached.

The applicable subheading for the “Tricky Wrench™” will be 8204.11.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives and extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: nonadjustable, and parts thereof: other (including parts). The rate of duty will be 9% ad valorem.

The applicable subheading for the “The Perfect Caulk Cutter™” will be 8214.90.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of cutlery (for example, hair clippers, butchers' or kitchen cleavers, chopping or mincing knives, paper knives); manicure or pedicure sets and instruments (including nail files); base metal parts thereof: other: other (including parts). The duty rate will be 1.4¢ each plus 3.2% 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 Kathy Campanelli at (646) 733-3021.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division