CLA-2-73:OT:RR:NC:N1:113
Mr. Kevin C. Prendiville
Kevin Prendiville
12619 Ridge Drive
Camarillo, California 93012
RE: The tariff classification of Swivel Snap Hooks from Taiwan
Dear Mr. Prendiville:
In your letter dated March 31, 2020, you requested a tariff classification ruling. Photographs of the Swivel Snap Hooks were provided for our review.
In your letter you described the first item under consideration as a Swivel Snap Hook made of cast iron with a 1" eyelet. This snap hook measures approximately 1.45" in width by 3.17" in height and weighs 68 grams. The second item in question is described as a Swivel Snap Hook made of cast iron with a 2" eyelet. This snap hook measures approximately 2.45" in width by 3.3" in height and weighs 69 grams. Each snap hook will be used as a connecting hook for a shoulder strap for a leather messenger bag.
You proposed classification for the Swivel Snap Hooks made of cast iron with 1" and 2" eyelets under subheading 8308.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for clasps, frames with clasps, buckles, buckle clasps, hooks, eyes, eyelets and the like and parts thereof, of base metal, of a kind used for clothing, footwear, awnings, handbags, travel goods or other made up articles…: hooks, eyes and eyelets.” However, this office disagrees. The subject Swivel Snap Hooks are described as “a connecting hook for a shoulder strap for a leather messenger bag.” The Explanatory Notes to the Harmonized Commodity Description and Coding System for heading 83.08 describe fasteners which are of a type of clasp such that you would find to keep items closed and private. The instant articles do not reflect that characteristic and simply connect the strap to the messenger bag. Based on the description, the subject connecting hook is not a closing mechanism and, as such, cannot be classified in heading 8308, HTSUS.
The applicable subheading for the Swivel Snap Hooks with a 1" eyelet (item 1) and the Swivel Snap Hooks with a 2" eyelet (item 2) will be 7326.90.8688, HTSUS, which provides for other articles of iron or steel, other, other…other. The rate of duty will be 2.9 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 the 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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division