CLA-2-84:OT:RR:NC:N1:102
Mr. Lawrence M. Friedman
Barnes, Richardson & Colburn
303 East Wacker Drive
Suite 1020
Chicago, IL 60601
RE: The tariff classification of a stainless steel freezer/refrigerator handle from China
Dear Mr. Friedman:
In your letter dated October 31, 2011 you requested a tariff classification ruling on behalf of your client, Electrolux Home Products, Inc. Descriptive literature and a photograph were included with your submission.
The item under consideration is a stainless steel freezer/refrigerator handle. The handle is approximately 28 inches long, 1¼ inches wide and 2 inches tall and is used to open the door of an upright or vertical type household freezer or refrigerator.
You suggest classification of the handle in subheading 8302.49.8090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articles…other mountings, fittings and similar articles, and parts thereof, other, other, other, other or in heading 7326, HTSUS, which provides for other articles of iron or steel.
The instant stainless steel handle is designed for use on freezers and refrigerators. Refrigerators and freezers do not have the characteristics of and are not similar or akin to the articles named in the terms of heading 8302, namely furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, and caskets. The subject handle, therefore, is not suitable for these articles and cannot be classified in heading 8302, HTSUS. With regard to heading 7326, HTSUS, the handle is more specifically provided for in another heading of the tariff and therefore cannot be classified in heading 7326, HTSUS.
In your request, you also propose classification of the handle in subheading 8418.99.8060, which provides for other parts of refrigerating or freezing equipment. Based on the information made available, the subject handle is designed solely or principally for use with a particular style household freezer or refrigerator door. As such, we find that the handle is provided for as a part of refrigerating equipment in heading 8418, HTSUS. However, the handle is used with household type refrigerators and is more specifically provided for elsewhere in subheading 8418.99.80, HTSUS.
The applicable subheading for the stainless steel freezer/refrigerator handle will be 8418.99.8050, HTSUS, which provides for other parts of combined refrigerator-freezers fitted with separate external doors and parts of household type refrigerators. The rate of duty is free.
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 Kenneth T. Brock at (646) 733-3009.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division