CLA-2-73:S:N:N3:113 810664

Ms. Jasmin Adjemian
Mittelstaedt, Galaviz and Mylin, Inc.
450 Sansome Street, Suite 200
San Francisco, CA 94111-3310

RE: The tariff classification of cookware parts from Hong Kong

Dear Ms. Adjemian:

In your letter dated May 11, 1995, on behalf of Meyer Corporation, you requested a tariff classification ruling.

The merchandise consists of three parts used with cookware. The rivet is made of aluminum and topped with a stainless steel cap. It is used to join the cookware to its handle. The aluminum represent 82 percent of the weight of the rivet.

The phenolic handle consists of a stainless steel insert within a phenolic shell. The stainless steel insert will be riveted to the body of the cookware and provides the handle with its structure. In our opinion, it gives the item its essential character.

The stainless steel lid consists of a stainless steel body and screw, with a phenolic handle. The lid is used to cover the cookware.

The applicable subheading for the rivet will be 7616.10.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of aluminum, rivets. The duty rate will be 4.7 percent ad valorem.

The applicable subheading for the handle and lid will be 7323.93.0030, Harmonized Tariff Schedule of the United States (HTS), which provides for table, kitchen or other household articles and parts thereof, of iron or steel, of stainless steel, cooking and kitchen ware. The duty rate will be 3.1 percent ad valorem. 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