CLA-2-82:OT:RR:NC:1:118

Mr. James C. Alberdi
A.J Arango, Inc.
1516 E. 8th Avenue
Tampa, FL 33605

RE: The tariff classification of multi-function tools from China.

Dear Mr. Alberdi:

In your letter dated March 3, 2009, on behalf of Hit Promotional Products, you requested a tariff classification ruling. The submitted samples are being returned as you requested.

You have submitted three samples for review. Item 5554 is described as a 4 in 1 mini multi-function tool. It is constructed of metal and measures approximately 1 ¼” W x 3” H. There is a fixed bottle opener at one end, a fold out LED light along the side of the housing and a knife blade which folds out on the opposite side from the light. There is a small compass on the outside of the housing. You refer to item 7225 as a multi-function tool in case. This metal tool opens to expose needle nose pliers. Encased within the open handle are said to be two foldout knife blades, a wire cutter, metal/wood file, a ruler with scaler and fish hook remover, bottle opener, flat head screwdriver, Philips head screwdriver and punch. Item 7221 is identified as a metal multi-function pliers with tools and flashlight in case. This tool has two handles that contain a folding knife, wire cutter, Philips head screwdriver, flat head screwdriver, bottle opener, file and LED flashlight and opens to reveal needle nose pliers.

The applicable subheading for items 5554, 7225 and 7221 will be 8211.93.0030, Harmonized Tariff Schedules of the United States (HTSUS), which provides for knives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof: other: knives having other than fixed blades: pen knives, pocket knives and other knives which have folding blades. The duty rate will be 3¢ each + 5.4% 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