CLA-2-83:S:N:N3:113 801785

Mr. Walter M. Cline
J. Cortina, Inc.
603 E. Jackson Street
Tampa, Fl 33602

RE: The tariff classification of the GunLok from Taiwan

Dear Mr. Cline:

In your letter dated August 24, 1994, you requested a tariff classification ruling.

The merchandise is the GunLok Motion Activated Trigger Alarm. The item consists of three parts: the key, the main housing and the foot. It is about 2 1/2 inches by 2 1/4 inches by 2 3/4 inches. The main housing contains a key-operated padlock of pin tumbler construction, and an electronic lock that is activated by motion. The shackle of the lock is intended to pass through the trigger guard of a firearm so that it cannot be discharged. The housing is of plastic, the lock of metal. In the opinion of this office, the essential character of this article is the lock.

The applicable subheading for the GunLok will be 8301.10.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for padlocks and locks (key, combination or electrically operated), of base metal, of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The duty rate will be 4.8 percent ad valorem. Your inquiry does not provide enough information for us to give a classification ruling on the question of the deductibility of the US-made electronic chip. Your request for a classification ruling should include all details relating to the assembly or manufacturing processes performed in Taiwan. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport