CLA-2-85:OT:RR:NC:N1:103
Jeongeun Kim
Cusan Customs Service Incorporation
#309, 35, Magokjungang 2-ro, Gangseo-gu
Seoul 07806
South Korea
RE: The tariff classification of a magnetizer from South Korea
Dear Ms. Kim:
In your letter dated June 19, 2025, you requested a tariff classification ruling on behalf of your client, EZEN
Korea Co., Ltd.
The merchandise under consideration is identified as the E-Zen multi-function magnetizer, model EQ-110,
and is described as an accessory for 1/4-inch hex bits. It consists of a cylindrical polyethylene body with a
knurled grip and a slight taper at one end. Inside the body is a hollow steel core equipped with a neodymium
ring magnet at each end. The magnetizer is used to temporarily add, strengthen, or remove magnetic fields
from driver bits or screwdrivers. Its overall dimensions are approximately 18.8 millimeters in diameter and
20.5 millimeters in length.
General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in
part that for legal purposes, classification shall be determined according to the terms of the headings and any
relative section or chapter notes. Goods that are, prima facie, classifiable under two or more headings, are
classifiable in accordance with GRI 3, HTSUS. GRI 3(a) states in part that when two or more headings each
refer to part only of the materials or substances contained in mixed or composite goods, those headings are to
be regarded as equally specific in relation to those goods, even if one of them gives a more complete or
precise description of the goods. GRI 3(b) states in part that composite goods consisting of different materials
or made up of different components, which cannot be classified by reference to 3(a), shall be classified as if
they consisted of the material or component which gives them their essential character, insofar as this
criterion is applicable. In our view, the essential character of the subject magnetizer is imparted by the
neodymium ring magnets.
As such, the applicable subheading for the E-Zen multi-function magnetizer, model EQ-110, will be
8505.11.0070, HTSUS, which provides for “Electromagnets; permanent magnets and articles intended to
become permanent magnets after magnetization; electromagnetic or permanent magnet chucks, clamps and
similar holding devices; electromagnetic couplings, clutches and brakes; electromagnetic lifting heads; parts
thereof: Permanent magnets and articles intended to become permanent magnets after magnetization: Of
metal: Sintered neodymium-iron-boron.” The general rate of duty will be 2.1 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. At this time products from all 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
8505.11.0070, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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
(CFR), 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 CFR 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 Huang at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division