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HQ 087115

August 31, 1990

CLA-2 CO:R:C:G 087115 SLR


TARIFF NO.: 4202.19.0000; 7326.90.9090; 9403.20.0030

Mr. R.C. Willette
A.N. Deringer, Inc.
30 West Service Road
Champlain, NY 12919-9703

RE: Metal Tool Chests and Boxes

Dear Mr. Willette:

This ruling is in response to your letter of April 27, 1990, on behalf of your client, SPG International Ltee. of Drummondville, Quebec, Canada, requesting the proper classification of various metal tool chests and boxes under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). Illustrations were provided for our examination.


Five items are the subject of this inquiry. They are all made of steel and described as follows:
a) Circular Saw Box - Model B-533 - measures 14-3/4" x 12" x 10-1/2" and features a top carrying handle.
b) Machinist Tool Chest - Model B-512 - measures 26" x 12" x 14-1/2" and features side handles. It includes 11 drawers and a tote tray.
c) 11 Drawer Cabinet - Model B-496 - measures 29" x 18-3/4" x 41-1/2" and is floor standing with casters.
d) Mechanic's Chest Base 2 Drawers - Model B-505 - measures 26-5/8" x 12-1/2" x 9-5/8" and is designed to fit models B-502 and B-503 as well as roller cabinet models B-498 and B-500.
e) Tote Tray - Model T-515 - is a shallow, open rectangular-shaped container which holds small tools or loose items. An elevated bar which stretches the length of the tray acts as a handle. While the tray may be carried independently, it is nonetheless designed to rest inside a tool box.


What is the proper classification of the subject metal tool chests and boxes under the HTSUSA?


Classification of merchandise under the HTSUSA is in accordance with the General Rules of Interpretation (GRI's), taken in order. GRI 1 provides that classification is determined according to the terms of the headings and any relative section or chapter notes.

Although not legally binding, the Explanatory Notes to the Harmonized Tariff Schedule represent the official interpretation of the tariff at the international level. The Notes offer guidance in understanding the scope of the provisions within each chapter of the Schedule.

Circular Saw Box & Machinist Tool Chest

Heading 7326, HTSUSA, provides for other articles of iron or steel. The Explanatory Note to 7326 lists tool boxes among those articles deemed exemplars of heading 7326. The Note, however, also excludes articles of heading 4202.

Heading 4202, HTSUSA, provides for trunks, suitcases, vanity cases, attache cases, briefcases, school satchels and similar containers (emphasis added). The Explanatory Note to heading 4202 indicates that the expression "similar containers" in the first part of the heading includes "hat boxes, camera accessory cases, cartridge pouches, sheaths for hunting or camping knives, etc."

Here, the subject tool boxes store and protect their contents. The existence of handles, however, renders these otherwise stationary boxes portable containers. Like hat boxes, camera accessory cases, etc., the composition of the instant tool boxes is commensurate with the items they carry. As the tool boxes are similar to the containers specifically enumerated in the first part of heading 4202 and no restriction regarding the materials comprising their composition appears within that part, the subject tool boxes are classifiable in heading 4202.

Subheading 4202.19, HTSUSA, provides for trunks, suitcases, vanity cases, attache cases, briefcases, school satchels and similar containers, of materials other than leather, plastics, or textile fabric. Classification in this subheading, as opposed to classification in 4202.99, the last "other" in heading 4202, is based on Customs determination that the articles listed before the semicolon in the heading text may be of any material, whereas
the articles after the semicolon must be composed of the named materials in that portion of the heading text, and, further, that the order or sequence of subheadings corresponds to the order or sequence of the heading text. Consequently, the portable tool cases of steel would be classified in subheading 4202.19.0000, HTSUSA.

Mechanic's Chest Base 2 Drawers & Box Tray

As the Mechanic's Chest Base 2 Drawers tool box does not have handles and does not appear to be designed to transport tools from place to place, it is not of the type of tool box classifiable in heading 4202. Consequently, it is classifiable in heading 7326 as an other article of steel.

The Box Tray is classifiable as an other article of steel in heading 7326, not as a similar container in heading 4202. The tray is designed to be placed inside a tool box, not to be carried individually.

11 Drawer Cabinet

While heading 7326 provides for other articles of iron or steel, the Explanatory Notes to that heading exclude shelved furniture of heading 9403.

Heading 9403, HTSUSA, provides for other furniture and parts thereof. The Explanatory Notes to Chapter 94 indicate that for the purposes of this chapter, the term "furniture" means:

Any "movable" articles...which have the essential characteristic that they are constructed for placing on the floor or ground, and which are used, mainly with a utilitarian purpose, to equip private dwellings...offices....

As the subject article stores tools within the home or office, is floor standing with casters and contains shelves, it is classifiable as other furniture in heading 9403.


The Circular Saw Box and Machinist Tool Chest are classifiable in subheading 4202.19.0000, HTSUSA, which provides for trunks, suitcases, vanity cases, and similar containers, other. The rate of duty is 20 percent ad valorem.

The Mechanic's Chest Base 2 Drawers and the Tool Box Tray are classifiable in subheading 7326.90.9090, HTSUSA, which provides for other articles of iron or steel, other. The rate of duty is 5.7 ad valorem.

The 11 Drawer Cabinet is classifiable in subheading 9403.20.0030, HTSUSA, which provides for other furniture and parts thereof, other metal furniture. The rate of duty is 4 percent ad valorem.

Goods classifiable under subheadings 4202.19.0000, 7326.90.9090, and 9403.20.0030, HTSUSA, which have originated from the territory of Canada, will be entitled to a 12 percent, 4.5 percent, and 2.4 percent rate of duty respectively under the United States-Canada Free Trade Agreement upon compliance with all applicable regulations.


John Durant, Director

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