CLA-2-79:OT:RR:NC:N1:164
Laura Oliver
A.N. Deringer
173 West Service Road
Champlain, NY 12919
RE: The tariff classification of spin cast zinc alloy keychains from Canada
Dear Ms. Oliver:
In your letter dated April 17, 2025, you requested a tariff classification ruling for spin cast zinc alloy
keychains from Canada on behalf of your client, Faro Products.
The items under consideration are described as spin cast zinc alloy keychains which are manufactured as
promotional products and for souvenir industries. At importation, each keychain consists of a steel split ring,
a cast zinc alloy ornament, and a steel jump ring (to connect the split ring to the cast zinc alloy ornament).
The cast zinc alloy ornament is shaped and jet printed to feature the logo or representation of a company,
sports team, or brand. In subsequent correspondence, you confirmed that the zinc alloy ornament accounts for
approximately 87 percent of the material composition by weight and approximately 85 percent of the material
cost of each keychain. Each keychain weighs approximately 39.3 grams.
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.
Section XV Note 5(a), HTSUS, states that an alloy of base metals is to be classified as an alloy of the metal
which predominates by weight over each of the other metals. As described, the subject zinc alloy will be
treated as zinc for classification purposes. In addition, Section XV Note 7, 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. In this case, the spin cast
zinc alloy keychains are composed of more than one base metal (zinc and steel), and zinc predominates by
weight. Consequently, the spin cast zinc alloy keychains are classifiable in heading 7907, HTSUS, which
provides for other articles of zinc.
The applicable subheading for the spin cast zinc alloy keychains will be 7907.00.6000, HTSUS, which
provides for Other articles of zinc: Other. The general rate of duty will be 3 percent ad valorem.
Products of Canada as provided by heading 9903.01.10 in Section XXII, Chapter 99, Subchapter III, U.S.
Note 2(j), HTSUS, other than products classifiable under headings 9903.01.11, 9903.01.12, 9903.01.13,
9903.01.14, and 9903.01.15, HTSUS, will be subject to an additional 25 percent ad valorem rate of duty. At
the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.10, in addition to
subheading 7907.00.6000, HTSUS, listed above. Articles that are entered free of duty under the terms of
general note 11 to the HTSUS (U.S.-Mexico-Canada Agreement (USMCA)), including any treatment set
forth in subchapter XXIII of Chapter 98 and subchapter XXII of chapter 99 of the HTSUS, will not be
subject to the additional ad valorem duties provided for in heading 9903.01.10. If your product is entered
duty free as originating under the USMCA, you must report heading 9903.01.14, HTSUS, in addition to
subheading 7907.00.6000, HTSUS.
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. Your product falls within an
excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.26, HTSUS, in addition to subheading 7907.00.6000, 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