CLA-2-74:OT:RR:NC:N1:164
Patrick Klein
Neville Peterson LLP
55 Broadway, Suite 2602
New York, NY 10006-3744
RE: The tariff classification of snap hooks from multiple countries
Dear Mr. Klein:
In your letter dated July 25, 2025, you requested a tariff classification ruling regarding snap hooks from
multiple countries on behalf of your client, Keystone Manufacturing and Supply, LLC. Product information
was submitted with your request.
The items under consideration are four models of snap hooks which will be used as connection hardware.
Model 225B (from Malaysia, Taiwan, or Vietnam) is composed of brass (61% copper, 35% zinc, 4% other
material) and features a round 1-inch eye, 3/8-inch opening, and an overall length of 3 5/8 inches. Model
5013Z (from Taiwan) is composed of diecast zinc, with nickel finish, and features a round 1-inch eye,
3/8-inch opening, and an overall length of 3 1/8 inches. Model 5015Z (from Taiwan) is composed of diecast
zinc, with nickel finish, and features a square 1-inch eye, a 3/8-inch opening, and an overall length of 2 1/2
inches. Finally, model 4901Z (from Taiwan) is composed of diecast zinc, with nickel finish, and features a
square 1-inch eye, a 1/4-inch opening, and an overall length of 2 1/2 inches. Based on the submitted
documentation, all models feature a hook, a safety snap to prevent an item from escaping the inner surface of
the hook, and a swiveling eye.
You proposed classification for the subject snap hooks under subheading 8308.10.0000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for Clasps, frames with clasps, buckles, buckle
clasps, hooks, eyes, eyelets and the like and parts thereof, of base metal, of a kind used for clothing,
footwear, awnings, handbags, travel goods or other made up articles…: Hooks, eyes and eyelets. However,
this office disagrees.
Classification under the 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).
First, Headquarters ruling 954696 (December 9, 1993) stated, in part, that snap hooks are not provided for eo
nomine in any heading. As a result, further analysis is required. It is our determination that the subject snap
hooks contain significant additional functionality that removes them from the generic term “hook” in the
context of heading 8308 and places them elsewhere. In support of this conclusion, the ENs specifically
exclude snap hooks from heading 8308 and specifically include them in the ENs to heading 7326, which
provides for other articles of iron or steel. Although the snap hooks at issue are not of iron or steel, the ENs to
headings 7419 (Other articles of copper) and 7907 (Other articles of zinc) make clear that both headings
provide for articles of the types listed in the ENs to heading 7326.
Section Note XV Note 5, HTSUS, states, in part, that an alloy of base metals of this section is to be classified
as an alloy of the metal which predominates by weight over each of the other metals. Additionally, an alloy
composed of base metals of this section and of elements not falling within this section is to be treated as an
alloy of base metals of this section if the total weight of such metals equals or exceeds the total weight of the
other elements present. Accordingly, the brass snap hooks, which are an alloy in which copper predominates
over zinc and other unspecified materials, are classified as other articles of copper.
The applicable subheading for the brass snap hooks (model 225B) will be 7419.80.5050, HTSUS, which
provides for Other articles of copper: Other: Other: Other: Other. The general rate of duty will be Free.
The applicable subheading for the zinc snap hooks (models 5013Z, 5015Z, 4901Z) 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.
On July 30, 2025, Presidential proclamation 10962 imposed additional tariffs on certain semi-finished copper
and intensive copper derivative products. Additional duties for semi-finished copper and intensive copper
derivative products of 50 percent upon the value of the copper content are reflected in Chapter 99, heading
9903.78.01. The non-copper content of these products, provided for in heading 9903.78.02, is not subject to
the additional ad valorem duties. At the time of entry, for the copper content you must report heading
9903.78.01, in addition to subheading 7419.80.5050, HTSUS. For the non-copper content, you must report
heading 9903.78.02, in addition to subheading 7419.80.5050.
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 of Malaysia will be
subject to an additional ad valorem rate of 19 percent, products of Taiwan will be subject to an additional ad
valorem rate of duty of 20 percent, and products of Vietnam will be subject to an additional ad valorem rate
of duty of 20 percent. Products classified in headings 7419.80.5050 and 7907.00.6000 fall in an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e., 9903.01.32, in addition to subheadings 7419.80.5050 and 7907.00.6000, HTSUS.
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
(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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division