CLA-2-82:S:N:N1:119 874421
Ms. Cecilia Castellanos
Withrow, Zerwekh & Co.
P.O. Box 368
Wilmington, CA 90748
RE: The tariff classification of a styling razor set from Japan
Dear Ms. Castellanos:
In your letter dated May 7, 1992, you requested a tariff
classification ruling on behalf of Japan America Trading Agency,
Inc., Los Angeles, CA.
The three components of the set are a styling razor, a package
of 10 styling blade units and a used blade disposal case.
The styling razor is approximately 7 1/4 inches in overall
length and consists of a plastic handle with finger loop, a metal
blade holder, a blade unit and a safety plastic sleeve to shield
the blade when not in use.
The blade unit itself is composed of two parts: a folded
flat piece of metal having a combed guard on the protruding edge
and forming a tight slit to grip the cutting blade. The blade
unit is 2 1/4 inches long.
The plastic used blade disposal case measures 2 1/2 inches
in length, 1 3/4 inches in width and 2 inches in height. It has
a long slit at the top to receive the used blades.
The three components of the set are designed in such a way
that the user can load a blade unit into the razor and dispose of
that blade unit without touching it.
We note that various dictionary definitions state that a
razor is used for "shaving the face or trimming the hair" (Random
House College Dictionary), "shaving or cutting the hair"
(Webster's Third New International Dictionary). Although the
styling razor is not used to shave hair from the skin but to
shape, taper or feather hair by professional hairdressers, it is
nevertheless a razor used to cut hair.
If imported separately the three articles would be
classified as follows.
The styling razor would be classified under subheading
8212.10.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for razors. The rate of duty would be 0.4
cent each plus 1 percent.
The blade units would be classified under subheading
8212.90.0000, HTS, which provides for razors and razor blades...
and base metal parts thereof... other parts. The rate of duty
would be 4.9 percent.
The used blade disposal case would be classified under
subheading 3926.90.9090, HTS, which provides for other articles
of plastics... other. The rate of duty would be 5.3 percent.
If the three articles are imported packaged together for
retail sale, they would be classified as a set whose essential
character is imparted by the styling razor. The complete set
would then be classified under the provision for razors in
subheading 8212.10.0000 and assessed duty at 0.4 cent each plus 1
percent. The specific rate (0.4 cent) is to be assessed on one
complete styling razor, one blade disposal case and 10 blades.
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.
The sample is being returned as requested.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport