CLA-2-63:OT:RR:NC:N3:351
Mr. Michael Rowles
DJR Logistics, Incorporated
510 Herron Drive
Swedesboro, NJ 08085
RE: The tariff classification of a lanyard with a split ring, carabiner and/or bottle holder from China
Dear Mr. Rowles:
In your letter dated June 24, 2013, you requested a tariff classification ruling on behalf of your client, Kalan Limited of Lansdowne, Pennsylvania.
You submitted photographs of a textile lanyard in various styles. The ends are folded over and sewn to create a loop. One end may have a split ring or a rubber bottle holder while a metal carabineer is attached to the other end to attach to a belt, backpack, or such. The lanyards have various sayings woven into the threads, (“#1 Dad,” “Wild Thing,” and “I Love My Dog”).
The applicable subheading for the lanyards with split rings, carabiners and/or rubber bottle holders will be 6307.90.9889, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem.
You suggest that the correct classification for the lanyards is in subheading 7326.20.0071, HTSUS, which provides for other articles of iron or steel. In this case, the lanyard is a composite good made up of different materials, the woven textile fabric lanyard and the metal split ring, carabineer and/or rubber bottle holder. The metal split ring, carabiner, and rubber bottle holder are not separate, but rather are suspended component parts of the lanyard itself, of a kind that are normally incorporated to create “a cord or strap to hold something,” which is how a lanyard is commonly defined.
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 Mitchel Bayer at (646) 733-3102.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division