CLA-2-82:OT:RR:NC:N1:118
Ms. Beth Zaffran
Robinson Home Products
170 Lawrence Bell Drive
Suite 110
Williamsville, NY 14221
RE: The tariff classification of a Meat Mallet from China.
Dear Ms. Zaffran:
In your letter dated February 21, 2018, you requested a tariff classification ruling.
The imported merchandise is described as a meat mallet and is marketed under item numbers 54139 and 7480. The meat mallet is a household tool used in the kitchen for manually pounding and/or tenderizing meat into cutlets. The tool incorporates a stainless steel handle with a cast aluminum head. One side of the aluminum head is smooth for flat pounding and the other side has raised teeth for tenderizing. The head of the mallet tapers into a neck which is connected to the stainless steel handle by an ABS plastic seal.
Consideration was given to your proposed tariff number 7615.10.5040, Harmonized Tariff Schedule of the United States (“HTSUS”) which provides for Table, kitchen or other household articles and parts thereof, of aluminum; pot scourers and scouring or polishing pads, gloves and the like, of aluminum; sanitary ware and parts thereof, of aluminum: Table, kitchen or other household articles and parts thereof; pot scourers and scouring or polishing pads, gloves and the like: Other: Cooking and kitchen ware: Not enameled or glazed and not containing nonstick interior finishes: Other. However, General Rule of Interpretation (GRI) 1, HTSUS, states, in part, that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes. In this case, heading 8205, HTSUS, provides for a more specific description of the merchandise. Therefore, your proposed classification in incorrect.
The applicable subheading for the Meat Mallet, items numbers 54139 and 7480, will be 8205.51.6000, HTSUS, which provides for Handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: Other handtools (including glass cutters) and parts thereof: Household tools, and parts thereof: Of aluminum. The rate of duty will be 2.2¢/kg + 5% 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 https://hts.usitc.gov/current.
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 Anthony E. Grossi at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division