CLA-2-83:OT:RR:NC:N1:121
Kathy Trotta
Conair Corporation
150 Milford Road
East Windsor, NJ 08520
RE: The tariff classification of travel padlocks from China
Dear Ms. Trotta:
In your letter dated September 17, 2019 you requested a tariff classification ruling. The samples you submitted have been examined and will be retained by this office for reference.
The merchandise in question is two “Travel Smart by Conair” base metal, key-operated travel padlocks used to secure luggage. Both locks are described as “Travel Sentry Padlocks”.
The first padlock, item number TS2A01X, features a solid metal shackle, rust resistant brass construction, and includes two keys. It is 2 centimeters wide and can only be unlocked with a key. The second padlock, item TSB01TS, features a solid metal shackle, rust resistant brass construction with a plastic cover, and includes two keys. It is 3 centimeters wide and can only be unlocked with a key.
The applicable subheading for the Travel Sentry Padlocks, item numbers TS2A01X and item number TSB01TS base metal padlocks will be 8301.10.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Padlocks and locks (key, combination or electronically operated), of base metal… Padlocks: Of cylinder or pin tumbler construction: Not over 3.8 cm in width. The rate of duty will be 6.1 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8301.10.6000, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8301.10.6000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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