CLA-2-79:OT:RR:NC:N1:164
Min Xie PVH Corp. 285 Madison Ave. New York, NY 10017 RE: The tariff classification and country of origin of keychains Dear Min Xie: In your letter dated September 30, 2025, you requested a tariff classification and country of origin determination ruling regarding keychains. Product information was submitted with your request. The first item under consideration is described as a keyring (Style 4D0621G). It is composed of a spring-loaded zinc snap hook with swiveling eye, a 25-millimeter (mm) diameter iron split ring, a polyurethane trim patch, and a polyester loop strap. The snap hook is engraved with “Calvin Klein” on its body and “Calvin Klein” is stitched along the length of both sides of the loop strap. The second item under consideration is described as a keyring (Style 4D9921G). It is composed of a spring-loaded zinc alloy snap hook with swiveling eye, a 25-mm diameter iron split ring, a 9-mm diameter zinc jump ring, a leather patch, and two zinc decorative components which form a pendant when joined to the sides of the leather patch. The snap hook and bottom pendant component are engraved with “Calvin Klein,” and the inner portion of the top pendant component is shaped into “cK.” You state that the manufacturing process of both styles occurs in Bangladesh. For style 4D0621G, you confirm that all components are from China. First, the polyurethane trim patch is looped around the eye of the fully manufactured and finished zinc snap hook. Then, the polyester loop strap is stitched into the inner surfaces of the polyurethane trim patch. After that, the iron split ring is inserted onto the eye of the snap hook and secured. For style 4D9921G, you confirm that all components are from China except the iron split ring which is from Taiwan. First, the iron split ring is inserted onto the eye of the snap hook and secured. At that point, the leather patch is inserted between the two decorative zinc components and pressed together into one decorative pendant. Finally, the zinc jump ring is inserted through an opening on the decorative pendant and through the eye of the snap hook to form a connection between all components.
Classification 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. As the keychains are composite goods, 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. Explanatory Note 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 snap hooks, split rings, or other components impart the essential character to the keyrings. In this case, the functional prominence of the metal snap hooks and split rings exceeds the utility the non-functional, decorative components. Both the snap hook and split ring provide a user the ability to attach to and securely hold a variety of objects, such as keys, during use. Between the two components, the snap hooks in both styles are substantially greater in weight and are mechanical in nature. On balance, the other components provide significantly less utility and are primarily for decoration and branding. Furthermore, Section XV, Note 7 of the 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. The metal in the subject keychains that predominates by weight is zinc. Therefore, the articles in question are classifiable as articles of zinc. The applicable subheading for the keychains (styles 4D0621G and 4D9921G) 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. Country of Origin When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In the instant case, finished components from China and Taiwan are imported into Bangladesh to be combined. Based on the description provided, the combining of finished components in Bangladesh amounts to a simple assembly process. Among the component parts, the spring-loaded snap hooks from China contribute the greatest levels of functionality and mechanical complexity to both styles of keyrings. Consequently, the simple assembly of the predominant snap hooks from China with other less-significant components in Bangladesh does not constitute a substantial transformation. Accordingly, the country of origin for both styles of keyrings will be China. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 7907.00.6000, HTSUS, listed above.
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 China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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. 9903.01.32, in addition to subheading 7907.00.6000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7907.00.6000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 7907.00.6000, 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, including information on exclusions and their effective dates, 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/programs-administration/trade-remedies, respectively. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division