CLA-2-84:S:N:N1:103 898802

Mr. David J. Loveday
Imperial Tobacco Limited
3810, rue St-Antoine Street
Montreal, P.Q. Canada H4C 1B5

RE: The tariff classification of tobacco kits from Canada

Dear Mr. Loveday:

In your letter dated June 2, 1994 you requested a tariff classification ruling.

You submitted information regarding two tobacco kits, a starter kit and a refill kit. The starter kit will consist of the following individual items (all values shown are in Canadian dollars):

1. A tin of fine cut cigarette smoking tobacco, composed of Brazilian leaf processed in Canada, valued at $0.89.

2. A box of 200 cigarette paper tubes with filters, made in Canada from paper of U.S. origin ($0.10).

3. A plastic cigarette rolling machine, made in Germany ($4.00).

4. A metal box for carrying cigarettes, made in the United Kingdom ($0.75).

5. An instruction leaflet, produced in Canada ($0.25).

These items will be packed in a cardboard box with a plastic film window through which the purchaser can see the items. They will be held in place inside the box in a plastic molded base. The outer box and molded base are both of Canadian origin and are valued at $0.65 and $0.02 respectively.

The refill kit will consist of the 6 ounce tin of tobacco and the box of 200 paper tubes. The starter kit and the refill kit are sets intended for retail sale, and thus they are classifiable in accordance with General Rule of Interpretation 3(b). GRI 3(b) holds, in pertinent part, that goods put up in sets for retail sale are classifiable in accordance with the material or component which gives them their essential character.

The essential character of the starter kit is imparted by the cigarette rolling machine. Therefore, the applicable subheading for the starter kit will be 8478.10.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for other machinery for preparing or making up tobacco, not specified or included elsewhere.... The rate of duty will be 4.2 percent ad valorem. In addition, the cigarette paper tubes are subject to a Federal Excise Tax pursuant to 26 U.S.C. 5701 of 1.5 cents per 50 tubes.

The essential character of the refill kit is imparted by the tobacco. Accordingly, the applicable subheading for the refill kit will be 2403.10.0040, HTS, which provides for smoking tobacco, whether or not containing tobacco substitutes in any proportion: in retail-sized packages: others. The rate of duty will be 38.6 cents per kilogram. Again, the cigarette paper tubes are subject to a Federal Excise Tax of 1.5 cents per 50 tubes.

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