CLA-2-82:OT:RR:NC:1:118
Ms. Jennie Crossley
Allstar Marketing Group, LLC
2 Skyline Drive
Hawthorne, NY 10532
RE: The tariff classification of Roto Punchers with eyelet sets and plastic carrying cases from China.
Dear Ms. Crossley:
In your correspondence dated February 8, 2012, you requested a tariff classification ruling.
You submitted two items for review. Item number 23587 is described as a Roto Puncher w/Eyelet Sets DLX P/2 and item number 23589 is described as a Roto Hole Punch Carrying Case P/2. You have stated that the Roto Puncher will be imported and sold packaged two to a box suitable for retail sale. Included in the box are two plastic bags, each containing one Roto Puncher with a small plastic bag containing 50 sets of assorted eyelets and snap-fasteners. You have advised us that the plastic carrying case will be imported independently of the Roto Puncher and sold packaged two to a box suitable for retail sale.
The Roto Puncher is a hand held tool used to punch holes and set eyelets and snap-fasteners in leather and fabric. It consists of two handles and two jaws working on a pivot. The upper jaw has a rotating five-pronged steel cutting head that cuts different hole diameters into leather or fabric. You have stated that the cutting heads contain by weight over 0.2 percent chromium. Along the rotating upper jaw is a separate raised portion with a hole and rubber collar that is used to accommodate the snap pins and snap rings when fastening them onto fabric. The lower jaw has a brass anvil which the cutting head aligns to for circular cuts. It also has a removable plastic component with a metal peg and rubber collar. This piece is added to the lower jaw when adding eyelets or snap fasteners to the fabric.
The applicable subheading for the Roto Hole Punch Carrying Case P/2, item number 23589, will be 3924.90.5650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for …other household articles…of plastics: other: other…other. The rate of duty will be 3.4 percent ad valorem.
The applicable subheading for Roto Puncher w/Eyelet Sets DLX P/2, item number 23587, will be 8203.40.3000, 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.
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,
Thomas J. Russo
Director
National Commodity Specialist Division