CLA-2-75:OT:RR:NC:N1:164
Shanel Kenney
Capezio
1 Campus Road
Totowa, NJ 07512
RE: The tariff classification of a split key ring with leather tag and strap from Thailand
Dear Ms. Kenney:
In your letter dated April 10, 2025, you requested a tariff classification ruling for a split key ring with leather
tag and strap from Thailand. You submitted a sample with your request.
The item under consideration is described as a split key ring with an attached leather tag and strap from
Thailand. The split key ring measures 1.125 inches in diameter and is made of nickel. The split design allows
the ring to slightly expand for keys to be inserted, pulled around the ring, and securely held in place. A
separate, small nickel loop is inserted into the split key ring that serves as an attachment point for an 8.5
centimeter-wide tag of 100 percent leather, cut and stitched to the appearance of a pair of shoes. Also
attached to the small nickel loop is a 100 percent leather loop strap measuring approximately 7.25 inches in
length.
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the
General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined
according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the
event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do
not otherwise require, the remaining GRIs 2 through 6 will then be applied in order.
The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official
interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the
scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these
headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989).
GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different
components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or
component which gives them their essential character.
Since the split key ring with attachments is a composite good, we must apply rule GRI 3(b), which provides
that composite goods are to be classified according to the component that gives the goods their essential
character. EN VIII to GRI 3(b) explains that “the factor which determines essential character will vary as
between different kinds of goods. It may, for example be determined by the nature of the material or
component, its bulk, quantity, weight or the use of the goods.”
We must determine whether the split key ring and loop of nickel or the leather attachments impart the
essential character. In this case, the function of the split key ring is to hold keys and the nickel loop holds
attachments. The leather loop strap has some functionality in that it can be used to hang the article on one’s
wrist or other object. Nonetheless, this is subservient to the primary function of holding keys. Based on the
submitted information, the leather tag is a decorative component which has no functionality. Therefore, it is
the opinion of this office that the split key ring of nickel imparts the essential character of the article because
it is the component that accomplishes the primary function of securely holding keys in place. In accordance
with GRI 3(b), the subject split key ring of nickel with leather attachments will be classified as an other
article of nickel.
The applicable subheading for the split key ring of nickel with attached leather tag and trap will be
7508.90.5000, HTSUS, which provides for Other articles of nickel: Other: Other. The general rate of duty
will be 3 percent ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to
subheading 7508.90.5000, HTSUS, listed above.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(C.F.R.), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 C.F.R. 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division