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NY 874421

June 4, 1992

CLA-2-82:S:N:N1:119 874421


TARIFF NO.: 8212.10.0000; 8212.90.0000; 3926.90.9090

Ms. Cecilia Castellanos
Withrow, Zerwekh & Co.
P.O. Box 368
Wilmington, CA 90748

RE: The tariff classification of a styling razor set from Japan

Dear Ms. Castellanos:

In your letter dated May 7, 1992, you requested a tariff classification ruling on behalf of Japan America Trading Agency, Inc., Los Angeles, CA.

The three components of the set are a styling razor, a package of 10 styling blade units and a used blade disposal case.

The styling razor is approximately 7 1/4 inches in overall length and consists of a plastic handle with finger loop, a metal blade holder, a blade unit and a safety plastic sleeve to shield the blade when not in use.

The blade unit itself is composed of two parts: a folded flat piece of metal having a combed guard on the protruding edge and forming a tight slit to grip the cutting blade. The blade unit is 2 1/4 inches long.

The plastic used blade disposal case measures 2 1/2 inches in length, 1 3/4 inches in width and 2 inches in height. It has a long slit at the top to receive the used blades.

The three components of the set are designed in such a way that the user can load a blade unit into the razor and dispose of that blade unit without touching it.

We note that various dictionary definitions state that a razor is used for "shaving the face or trimming the hair" (Random House College Dictionary), "shaving or cutting the hair" (Webster's Third New International Dictionary). Although the styling razor is not used to shave hair from the skin but to shape, taper or feather hair by professional hairdressers, it is nevertheless a razor used to cut hair.

If imported separately the three articles would be classified as follows.

The styling razor would be classified under subheading 8212.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for razors. The rate of duty would be 0.4 cent each plus 1 percent.

The blade units would be classified under subheading 8212.90.0000, HTS, which provides for razors and razor blades... and base metal parts thereof... other parts. The rate of duty would be 4.9 percent.

The used blade disposal case would be classified under subheading 3926.90.9090, HTS, which provides for other articles of plastics... other. The rate of duty would be 5.3 percent.

If the three articles are imported packaged together for retail sale, they would be classified as a set whose essential character is imparted by the styling razor. The complete set would then be classified under the provision for razors in subheading 8212.10.0000 and assessed duty at 0.4 cent each plus 1 percent. The specific rate (0.4 cent) is to be assessed on one complete styling razor, one blade disposal case and 10 blades.

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.

The sample is being returned as requested.


Jean F. Maguire
Area Director

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