CLA-2-82:RR:NC:N1:118 M81294

Ms. Francine Marcoux
Hampton Direct, Inc.
350 Pioneer Drive
P.O. Box 1199
Williston, VT 05495

RE: The tariff classification of a paper punch packed with 4 interchangeable punches from China.

Dear Ms. Marcoux:

In your letter, dated March 15, 2006, you requested a ruling on tariff classification.

The “Paper Puncher w/4 Interchangeable Punches,” item 54380, is a hand-held punch that is similar in function to a typical one-hole punch. The paper punch is packed with 4 interchangeable shapes that include a heart, tulip, Cupid with arrow, and a crescent moon. The punching hole mechanism is said to be made of a zinc alloy that does not contain any chromium, molybdenum, tungsten or vanadium. The balance of the punch is made of acrylonitrile-butadiene-styrene (ABS plastic). The item will be marketed for use in scrapbooking, card making, and creating invitations.

The applicable subheading for the paper punch packed with 4 interchangeable punches will be 8203.40.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof, pipe cutters, bolt cutters, perforating punches and similar tools, and parts thereof, other (including parts). The rate of duty will be 3.3 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR).

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 Kathy Campanelli at 646-733-3021.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division