CLA-2-85:RR:NC:2:227 I84711
Ms. Lisa Morales
Sun Manufacturing Corp.
15959 N.W. 15th Avenue
Miami, FL 33169
RE: The tariff classification of mini flashlights with key chains and snap hooks from China.
Dear Ms. Morales:
In your letter dated July 22, 2002, you requested a tariff classification ruling.
The samples submitted, referred to as “mini-key-hole-lights,” consist of the following articles:
item number SM-9771, is a circular plastic flashlight, that measures approximately 1 ¼ inches in diameter, which emits a red light when squeezed. A metal chain and key ring is attached to one end of the flashlight and a metal snap hook is attached to the other side.
item number SM-9791, is a circular plastic flashlight that measures approximately 1 ¼ inches in diameter, which emits a blue light when squeezed. A metal chain and key ring is attached to one side of the flashlight and a metal snap hook is attached to the other side.
You state that the articles should not be classified as flashlights as they do not produce enough illumination. However, the mini flashlights are designed and do produce a sufficient beam of light for detecting the keyway of a lock. Accordingly, the articles are composite goods with the essential character imparted by the flashlights.
The applicable subheading for the above items will be 8513.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for portable electric lamps designed to function by their own source of energy…lamps: flashlights. The rate of duty will be 12.5 percent ad valorem.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the 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 George Kalkines at 646-733-3028.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division