CLA-2-82:OT:RR:E:NC:N1:118

Ms. Carrie Laskavy
Import Compliance Specialist
Central Purchasing, LLC
3491 Mission Oaks Blvd.
Camarillo, CA 93012

RE: The tariff classification of metal hand punches from China.

Dear Ms. Laskavy:

In your letter dated February 19, 2008, you requested a tariff classification ruling for metal hand punches.

You have described both items as metal hand punches that operate by applying hand pressure to the grips. SKU 44060 punches holes in thin sheet steel, aluminum and brass as thick as 16 gauge. SKU 91510 is capable of punching holes from 1/8” to 7/16” in sheet metal, aluminum and brass as thick as 11 gauge. The punches are imported, packaged for retail sale, with interchangeable punches and dies. One of the elements within the cutting material for SKU 44060 contains more than 0.2% chromium.

The applicable subheading for metal hand punch SKU 44060 with the interchangeable punches and dies will be 8203.40.3000, 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: 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 6 percent ad valorem.

The applicable subheading for metal hand punch SKU 91510 with the interchangeable punches and dies will be 8203.40.6000, 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. 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 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 Kathy Campanelli at 646-733-3021.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division