CLA-2-83:OT:RR:NC:N1:121

Mr. Peter Bogard
Neville Peterson LLP
1400 16th Street, N.W. Suite 350
Washington, D.C. 20036

RE: The tariff classification of lids and caps from China

Dear Mr. Bogard:

In your letter dated October 13, 2015, you requested a tariff classification ruling on behalf of Klean Kanteen, Inc. The submitted samples will be returned per your request.

The products under consideration are two polypropylene lids and three stainless steel bottle caps. Each will be imported separately for use with Klean Kanteen drinking glasses, tumblers and/or bottles (not included).

Product KPNTLID-BK (Pint Lid) is a two-piece polypropylene and silicone plastic lid that measures 1" in height and has a diameter of 3.25". The lid is designed to be used with Klean Kanteen steel drinking glasses and tumblers. The lid features a silicone gasket around its circumference that forms a seal when it is attached to a drinking vessel. The top of the lid is indented, and a silicone disk is affixed to the center of the lid. The silicone disk can be rotated to cover and uncover an opening in the cap, so beverages can be poured out. The disk also features a hole in its center covered by three small flaps through which a straw can be inserted. Product KWPPC-BK (Café Cap) is a polypropylene plastic cap that measures 1" in height and has a diameter of 2.5". The cap is intended for use with Klean Kanteen bottles, and a threaded portion of the cap enables it to be screwed onto said bottles. The top of the cap features a rotating top disk that allows a user to cover and uncover an opening in the cap, so beverages can be poured out. Silicone gaskets on the interior of the cap and below the rotating disk protect against leaks. Product KCSSL-BS (All Stainless Steel Loop Cap) is a stainless steel cap that measures 2” in height and 2” in diameter. The cap is threaded at the base allowing it to be screwed into the neck of a Klean Kanteen bottle. A silicone gasket located below the top of the cap forms a seal when the cap is screwed onto the bottle. A stainless steel loop on the top of the cap enables the bottle to be attached to a backpack or other such article. Product KCSSLB-BS (Stainless Unibody Bamboo Cap) is a stainless steel cap that measures 2” in height and 2.25” in diameter. The cap is threaded at the base allowing it to be screwed into the neck of a Klean Kanteen bottle. A silicone gasket located below the top of the cap forms a seal when the cap is screwed onto the bottle. The top of the cap is covered with a decorative layer of bamboo and features a pivoting stainless steel loop that enables the bottle to be attached to a backpack or other such article. Product KCSLK-BS (Swing Lok Cap) is a stainless steel cap that measures 1.5” in height and 2” in diameter. The cap incorporates a pivoting stainless steel ring and latch that secure the cap to the bottle. A silicone gasket positioned at the base of the cap forms a seal. The applicable subheading for the KPNTLID-BK Pint Lid and KWPPC-BK Café Cap will be 3923.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics: Stoppers, Lids, Caps and other closures. The rate of duty will be 5.3% ad valorem. The applicable subheading for the KCSSL-BS All Stainless Steel Loop Cap, KCSSLB-BS Stainless Unibody Bamboo Cap, and the KCSLK-BS Swing Lok Cap will be 8309.90.0000, HTSUS, which provides for stoppers, caps and lids…and parts thereof, of base metal, other. The rate of duty will be 2.6 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 [email protected].

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division