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NY 874065

May 6, 1992

CLA-2-74:S:N:N1:115 874065


TARIFF NO.: 7419.99.3000

Ms. Pam Kalstein
Lapine Associates, Inc.
P.O. Box 10050
467 West Main Street
Stamford, CT 06904

RE: The tariff classification of a brass keychain from China.

Dear Ms. Kalstein:

In your letter dated April 20, 1992, you requested a tariff classification ruling.

The subject item is a two-piece functional keychain. One piece is comprised of a brass attachment. Underneath its lacquered coating, are several platings of gold, nickel and copper. The base metal composition is brass. The other piece, is a wire key loop or ring, which is also lacquer coated. The base metal of the ring is carbon steel.

Your merchandise is considered composite goods, consisting of different materials or made up of different components. This item shall be classified as if it consisted of the material or component which gives it its essential character. In this instance, the brass attachment imparts the essential character.

The applicable subheading for the brass keychain will be 7419.99.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of copper: other: coated or plated with precious metal. The duty rate will be 10% ad valorem.

Your query also requests a country of origin marking ruling on the keychain. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304) provides in general that any article of foreign origin (or its container) imported into the United States must be marked conspicuously, indelibly, legibly and as permanently as the nature of the article will permit in such manner as to indicate the country of origin to the ultimate purchaser in the United States.

The adhesive sticker that is on the underside of the brass attachment of the keychain is not permanent as the nature of the article will permit. A more permanent type of marking is required, such as die sinking or acid etching, for your product to be legally marked. In addition, it is noted that the adhesive label found on the sample is easily removed.

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

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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