CLA-2-83:OT:RR:NC:N1:121
David Borenstein
INTU-Keys Co.
5 William Street
Georgetown, Ontario
Canada, L7G 1Y2
RE: The tariff classification of a magnetic key blank from China
Dear Mr. Borenstein:
In your letter dated May 16, 2018, you requested a tariff classification ruling. The submitted sample was examined and will be retained by this office.
The merchandise under consideration is the “Magnetic Key,” product number 11468. The sample you submitted is a black colored, SC1 style, uncut key blank typically used for household doors. The key blank is made of anodized aluminum with a nickel-plated neodymium magnet press fit into the key head. The purpose of the “Magnetic Key” is for hiding or storing a spare key by attaching it to any ferrous metal surface, or connecting multiple keys to eliminate the need for a key ring.
The Magnetic Key is composed of different components (anodized aluminum and a nickel plated neodymium magnet) and is considered a composite good. The Explanatory Notes to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3 (b) (VIII), state that the factor which determines essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. When the essential character of a composite good can be determined, the whole product is classified as if it consists only of the material or component that imparts the essential character to the composite good. If no essential character for the composite good can be determined, then Rule 3 (c) provides that classification will be determined by the heading that occurs last in numerical order among those headings that equally merit consideration. By application of GRI 3 (b) this office finds that the anodized aluminum key blank imparts the essential character.
The applicable subheading for the Magnetic Key, product number 11468, will be 8301.70.0000, HTSUS, which provides for Padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys and parts of any of the foregoing articles, of base metal: Keys presented separately. The general rate of duty will be 4.5 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 https://hts.usitc.gov/current.
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 Jennifer Jameson at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division