CLA-2 CO:R:C:G 082870 WAW
Mr. Leslie Alan Glick
Porter, Wright, Morris & Arthur
1233 20th Street, N.W.
Suite 400
Washington, D.C. 20036
RE: Brass lamp parts
Dear Mr. Glick:
This ruling is in response to your letter of September 27,
1988, requesting the classification of certain brass lamp parts
under the Harmonized Tariff Schedule of the United States
Annotated (HTSUSA).
FACTS:
The articles at issue are various solid brass lamp parts.
The parts are designed for two different electric brass lantern
styles, Products #233 and #320. Product #233 consists of
thirteen different solid brass parts. The parts for Product #320
consist of sixteen different solid brass parts. The subject
merchandise will be reimported into the United States after
undergoing rough cutting, buffing, polishing and other operations
required to prepare the parts for assembly into finished brass
electric wall lamps in Mexico.
ISSUE:
What is the proper classification of brass lamp parts under
the HTSUSA?
LAW AND ANALYSIS:
The General Rules of Interpretation (GRI's) set forth the
manner in which merchandise is to be classified under the HTSUSA.
GRI 1 requires that classification be determined first according
to the terms of the headings of the tariff and any relative
section or chapter notes and, unless otherwise required,
according to the remaining GRI's, taken in order.
Heading 9405, HTSUSA, covers lamps and lighting fittings
including searchlights and spotlights and parts therof, not
elsewhere specified or included. Under heading 9405, HTSUSA,
there is a specific subheading which provides for lamp parts.
More specifically, subheading 9405.99.2000, HTSUSA, covers lamp
parts of brass. Since the instant lamp parts are of solid brass,
and they are designed for use as parts of brass lamps, it is
Customs position that they clearly fall within the purview of
subheading 9405.99.2000, HTSUSA.
HOLDING:
The brass lamp parts are classifiable under subheading
9405.99.2000, HTSUSA, which provides for parts of brass lamps and
lighting fittings. The applicable rate of duty is 5.7 percent ad
valorem.
Sincerely,
John Durant, Director
Commercial Rulings Division