CLA-2-85:OT:RR:NC:N1:112

David Andrew Happe
Blaze Your Own Path, Inc.
7760 France Avenue South
11th Floor, Suite #1109
Minneapolis, MN 55435

RE: The tariff classification of a personal keychain alarm from China

Dear Mr. Happe:

In your letter dated October 3, 2011, you requested a tariff classification ruling.

The item concerned is referred to as the Vigilant PPS22BL 130 dB Panic Rape Emergency Personal Alarm Keychain plus LED Light. This device is a battery-operated, personal alarm that is designed to resemble a car remote. It consists of a 130 decibel alarm and an LED light within a black plastic housing. Attached to the housing is a keychain. This unit operates on three LR44 batteries which are included.

The Vigilant PPS22BL 130 dB Panic Rape Emergency Personal Alarm Keychain plus LED Light is designed to be used as a personal safety device. It is particularly suitable for teenagers, parents, route employees, business owners and college students. When activated, this device is intended to draw attention to the user by issuing an audible distress signal. The ear-piercing high pitched alarm is activated by simply pulling a pin. It will issue a continuous alarm sound for up to one hour. The LED light provides a secondary/subsidiary function. The light is activated by a separate on/off button and is used for the illumination of a car door keyhole or for other low light situations.

The applicable subheading for the Vigilant PPS22BL 130 dB Panic Rape Emergency Personal Alarm Keychain plus LED Light will be 8531.80.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electric sound or visual signaling apparatus…: Other apparatus: Other sound signaling apparatus." The rate of duty will be 1.3%.

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 Steven Pollichino at (646) 733-3008.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division