CLA-2-73:RR:NC:1:118 E82835
Ms. Deanna DeVaney
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, OH 44130
RE: The tariff classification of a KL-Pin for use with a cutting insert holder from Great Britain.
Dear Mr. DeVaney:
In your letter dated May 26, 1999, you requested a tariff classification ruling on behalf of your client Kennametal Inc., Latrobe, PA.
You stated that the submitted sample is called a KL-Pin, model KLM-46. This steel product, approximately 5/8" in length, holds a cutting insert to a machine tool holder. It secures and retains the insert during cutting applications. It is hollow through the center with one end being threaded and the other end designed to be tightened by a hex allen wrench or similar tightening hand tool. Although this product is imported in many cases as a component of the various tool holders it is used with, there will be importations of KL-Pins in bulk. This ruling will address the classification of KL-Pins when imported separately.
The applicable subheading for the KL-Pin will be 7318.19.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers and similar articles, of iron or steel: threaded articles: other. The duty rate will be 5.7% ad valorem.
Consideration was given to classifying this product under subheading 8207.90.7585, HTS, as you have suggested. However, as the item acts as a fastener rather than as a tool, a tool holder, or as a tool part, that subheading has been deemed inappropriate.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Kathy Campanelli at 212-637-7025.
Sincerely,
Robert B. Swierupski
Director
National Commodity
Specialist Division