CLA-2-82:RR:NC:1:104 J82340
Mr. Chris Cammack
Irwin Industrial Tool Company
108 South pear Street
P.O. Box 337
DeWitt, NE 68341
RE: The tariff classification of lock installation kits and adjustable wrench parts from China
Dear Mr. Cammack:
In your letter dated March 13, 2003 you requested a tariff classification ruling.
The Metal/Wood Door Lock Installation Kit, Part # 17104, consists of two bi-metal hole saws, one center drill and mandrel, and one plastic jig packaged in a plastic clamshell. The drill bit is made of M2 high speed steel (HSS).
The Wood Door Lock Installation Kit, Part # 17105, consists of two carbon steel hole saws, one center drill and mandrel, and one plastic jig in a plastic clamshell. The drill bit is made of C1045 carbon steel.
Samples of both kits have been provided and will be returned per your request. You suggest classification in subheading 8207.50.6000 noting NY ruling H80305 of May 23, 2001 which classified a door lock installation kit as a GRI 3 (c) set. We concur with your classification for the Wood Door Lock Installation Kit, Part # 17105. The Metal/Wood Door Lock Installation Kit, Part # 17104, is also a GRI 3 (c) set however it meets the terms of the more specific subheading 8207.50.2080.
The final 3 items are aluminum die cast parts of an adjustable wrench. Samples have also been provided. The parts are made of A380 aluminum. The two pieces marked “Vise Grip” on the side will be bolted together around a steel bar to make a tool handle. The remaining piece will slide on the steel bar the handles are bolted to and will be the bottom jaw of an adjustable wrench.
You suggest classification under HTS subheading 7616.99.5060 as aluminum castings. The subheading provides for other articles of aluminum: other: other: other. Since these items are parts of an adjustable wrench of heading 8204, they are more specifically provided for in that heading.
The applicable subheading for the Metal/Wood Door Lock Installation Kit, Part # 17104, will be 8207.50.2080, Harmonized Tariff Schedule of the United States (HTS), which provides for interchangeable tools for handtools, whether or not power operated or for machine tools …: tools for drilling, other than rock drilling, and parts thereof: with cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium. The rate of duty will be 5 percent.
The applicable subheading for the Wood Door Lock Installation Kit, Part # 17105, will be 8207.50.6000, HTS, which provides for interchangeable tools for handtools, whether or not power operated or for machine tools …: tools for drilling, other than rock drilling, and parts thereof: other: not suitable for cutting metal, and parts thereof: for handtools, and parts thereof. The rate of duty will be 5.2 percent.
The applicable subheading for the adjustable wrench parts will be 8204.12.0000, HTS, which provides for hand operated spanners and wrenches, and parts thereof: adjustable, and parts thereof. The rate of duty will be 9 percent.
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 Robert Losche at 646-733-3011.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division