CLA-2-82:RR:NC:1:115 C86588
Mr. Louis S. Shoichet
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway
43rd Floor
New York, NY 10036-8901
RE: The tariff classification of a 14-in-1 Tool from China
Dear Mr. Shoichet:
In your letter dated April 8, 1998 on behalf of Avon
Products, Inc. you requested a tariff classification ruling.
The 14-in-1 tool is a steel-metal multi-purpose tool
measuring approximately 4 inches in length in the closed
position. The following components make up the tool: pliers,
wire cutter, knife, scissors, saw, file, serrated knife, can
opener, bottle opener, Philips head, 3 flat blade drivers and a
mini-pen light to illuminate the immediate tool surface. The
multi-purpose tool is specially fitted into a textile case and
imported as such.
The instant merchandise comprises a composite article with
various components. The headings at issue refer to part only of
the materials or substances contained in the composite good, and,
according to GRI 3(a), are to be regarded as equally specific,
thereby making resort to GRI 3(b) necessary as each of the
components contribute equally to the use of the article,
classification is determined by reference to GRI 3(c) which
provides for classification under those which equally merit
consideration.
The knife part of the total tool is last in the tariff, and
its subheading would be the basis of classification.
Accordingly, the multi-tool is classifiable in subheading
8211.93.0030, Harmonized Tariff Schedule of the United States
(HTS) at 3 cents each plus 5.4 percent ad valorem. Please note
the mini-pen light was not given any consideration under the
GRI's. The specially shaped and fitted case is of a kind
normally sold with the tool and is classified with its contents
in accordance with GRI 5(a).
The sample is being returned to your office in compliance
with your request.
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 Melvyn
Birnbaum at 212-466-5487.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division