CLA-2-73:OT:RR:NC:N1:113
Ms. Dawn Wood
AVT Leather Inc.
5210 Village Parkway
Rogers, AR 72758
RE: The tariff classification of key rings from India
Dear Ms. Wood:
In your letter dated April 2, 2014, you requested a tariff classification ruling. Samples of the subject key rings were submitted for our review.
The merchandise consists of six styles of key rings that are identified as style numbers KF 013 01, KF 013 03, KF 013 04, KF 013 07, KF 013 08 and KF 013 09. You indicated that the key rings are used for holding automobile and home keys on one ring. Each style of key ring under consideration features a different design.
Key ring style number KF 013 01 is composed of two iron split wire rings attached to a leather strap that measures approximately 1.5 inches in width by 3.5 inches in height. Key ring style number KF 013 03 is composed of two iron split wire rings attached to a leather strap that measures approximately 1.5 inches in width by 3.5 inches in height. A small zinc disk is permanently set into the front of the strap. Key ring style number KF 013 04 is composed of two iron split wire rings attached to a leather strap that measures approximately 1.5 inches in width by 3.5 inches in height. Key ring style numbers KF 013 07 and KF 013 08 are each composed of two iron split wire rings attached to a leather strap that measures approximately 1 inch in width by 2.5 inches in height. A zinc sliding snap hook with a connector link at the top is attached to a leather loop on one end of the strap. Key ring style number KF 013 09 is composed of two iron split wire rings attached to a leather strap that measures approximately 1.5 inches in width by 3.5 inches in height.
You stated that style numbers KF 013 07 and KF 013 08 are composed of more than one base metal. The key rings are composed of iron and zinc. Section XV, Note 7 of the Harmonized Tariff Schedule of the United States (HTSUS), states that the classification of composite articles of base metal containing two or more base metals are to be treated as articles of the base metal that predominates by weight over each of the other metals. The metal in key ring style numbers KF 013 07 and KF 013 08 that predominates by weight is zinc. Therefore, the key rings in question are classifiable in heading 7907, HTSUS, which provides for other articles of zinc.
The applicable subheading for key ring style numbers KF 013 07 and KF 013 08 will be 7907.00.6000, HTSUS, which provides for other articles of zinc, other. The rate of duty will be 3 percent ad valorem.
The applicable subheading for KF 013 01, KF 013 03, KF 013 04 and KF 013 09 will be 7326.20.0071, HTSUS, which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem.
Articles classifiable under subheading 7907.00.6000 and 7326.20.0071, HTSUS, which are products of India are currently entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term "GSP".
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 [email protected].
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division