CLA-2-83:RR:NC:N1:121
Ms. Tami Nelson
Targus
1211 N. Miller Street
Anaheim CA 92806
RE: The tariff classification of padlocks from China
Dear Ms. Nelson:
In your letter dated May 24, 2007, you requested a tariff classification ruling.
The sample you submitted, which will be retained by this office, is called the “Targus DEFCON® Notebook & iPod Lock Combo Set” (part number ASP13US). It consists of the following: an “Eyelet Security Lock for iPod,” a “DEFCON CL Notebook Computer Cable Lock”, and a “DEFCON Security Base Plate.”
The DEFCON CL Notebook Computer Cable Lock (part number PA41OU) is a combination padlock with four rotating, numbered dials. It is made of base metal with a 6.5 foot long, vinyl coated, galvanized steel cable. It attaches to any laptop computer equipped with a lock slot. It is used to secure a laptop computer to a stationary object, such as a desk or file cabinet.
The Eyelet Security Lock for iPod (part number ASP11US) is a combination padlock with three rotating, numbered dials. It is made of base metal with a 3.75 inch, vinyl coated, galvanized steel, looped cable. It is designed to be used in conjunction with a notebook lock. The end of the lock inserts into an iPod and cannot be detached until the user inputs the correct combination code and presses the release button. Once the eyelet lock is attached to the iPod, the cable from the notebook lock is threaded through the eyelet lock’s pass-through loop and then fastened to the notebook to secure both devices simultaneously.
The Security Base Plate (PA400P) is a base metal mounting designed to be anchored to a desk or work surface with both adhesive and screws. Once attached, the cable from the notebook lock is threaded through the mounting and then fastened to the notebook to provide maximum security.
You requested in your original letter, dated May 23, 2007, the tariff classification of these articles imported together as a set and also for each lock imported separately. You also indicated that you believe these locks to be accessories to ADP units since they are specifically designed to secure these items by inserting into docks and lock slots.
Heading 8301, Harmonized Tariff Schedule of the United States (HTSUS), provides for padlocks and locks of base metal. Both the DEFCON CL Notebook Computer Cable Lock and the Eyelet Security Lock for iPod meet the terms of this heading. Section XV, note 2(c) indicates that goods of heading 8301 are “parts of general use.” Section XVI, note 1(g) indicates that “parts of general use,” as defined in note 2 to section XV, are not covered in section XVI. Consequently, the locks are not classified as accessories to ADP units since they are precluded from classification within this section of the tariff.
The applicable subheading for the “Targus DEFCON® Notebook & iPod Lock Combo Set” (part number ASP13US) will be 8301.10.4000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…Padlocks, not of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The rate of duty will be 3.8 percent ad valorem.
The applicable subheading for the Eyelet Security Lock for iPod imported separately will be 8301.10.2000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…Padlocks, not of cylinder or pin tumbler construction, not over 3.8 cm in width. The rate of duty will be 2.3 percent ad valorem.
The applicable subheading for the DEFCON CL Notebook Computer Cable Lock imported separately will be 8301.10.4000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…Padlocks, not of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The rate of duty will be 3.8 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 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 Barbara Kaiser at 646-733-3024.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division