CLA-2-74:RR:NC:1:118 D80180

Mr. Anthony Cuschieri

International Packaging Films, Inc.

64 Hillside Ave.

Westwood, New Jersey 07675

RE: The tariff classification of decorative hardware from India.

Dear Mr. Cuschieri:

In your letter dated July 10, 1998, you requested a tariff classification ruling.

The subject items are described as follows:

1) 2" 135 degree ball side outlet elbow - This item would be used to hold brass tubing. It is a round shaped ball with three mm threaded outlets which would be capable of accommodating pipes or tubes. One of the best examples of where this product is used is in a salad bar, where a sneeze guard is utilized. The sneeze guard is hung over the salad bar and the brass tubing and fittings provide a framework where glass is employed to shield the food products on the food bar. Another potential application, could be as a handrail going up a set of stairs.

2) 2" glass clip - The largest application for a glass clip is in a restaurant or diner. Sometimes when sitting in a booth in a restaurant, two booths will have a glass partition on top of the sitting bench. The glass portion will provide some degree of privacy between the tables. The clip is used to hold the glass partition in place.

Both of these items will be threaded for screws only. They are not threaded in their condition as imported. In the case of the outlet elbow, each outlet has a small hole that is threaded. This hole will allow for a screw to be inserted and used to secure the elbow to the tube that is connected to it. The chemical analysis for both of these items is indicated to be 60% copper and 40% tin. This is a bronze alloy.

The applicable subheading for the 2", 135 degree ball side outlet elbow will be 7412.20.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for copper tube or pipe fittings (for example: couplings, elbows, sleeves): of copper alloys: other: other: other. The duty rate will be 3% ad valorem.

The applicable subheading for the 2" glass clip will be 8302.42.6000, HTS, which provides for base metal mountings, fittings and similar articles suitable for furniture: other mountings, and fittings: other: suitable for furniture: other. The duty rate will be 3.7% ad valorem.

The Generalized System of Preferences (GSP) expired at midnight, June 30, 1998. If the program is renewed by Congress, articles classifiable under subheading 7412.20.0090 and 8302.42.6000, HTS, which are products of India, will be entitled to duty free treatment under the GSP upon compliance with all applicable regulations.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this 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 212-466-5492.

Sincerely,

Robert B. Swierupski

Director

National Commodity

Specialist Division