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NY 875212

June 23, 1992

CLA-2-82:S:N:N1:115 875212


TARIFF NO.: 8201.30.0000; 9801.00.1082

Mr. Bruce Moore
Forrest Tool Company
P.O. Box 768
Mendocino, CA 95460

RE: The tariff classification of the "Max" Multipurpose Tool from China.

Dear Mr. Moore:

In your letter dated May 13, 1992, you requested a tariff classification ruling.

The subject item is designated as the "Max" Multipurpose Tool. This tool is in fact a system of tools designed to perform various functions. In its imported condition, the tool comprises the following:

1. U.S.A. hickory handle axe assembled to an axe head 2. Shovel attachment
3. Straight pick attachment
4. Chisel pick attachment
5. Mattock attachment
6. Reversible rake/hoe attachment

All of the articles (except the hickory handle) above are made of steel in China.

In addition, the following are also included in the boxed tool:
a) A thumbscrew and bar tightener (country of origin China) b) A leather axe sheath (country of origin U.S.A.) c) A canvas bag for holding attachments (country of origin U.S.A.)

The entire tool system is designed for use by such agencies as the U.S. Department of Agriculture, the Department of the Interior and the Army Corps of Engineers, etc. Several possible uses of this tool include the planting of seedlings, removing rocks, breaking up cement, digging wells, fighting forest fires, etc. Each of the individual attachment tools is designed to be attached to the axe head to create the second tool. The axe handle becomes the handle for a shovel or pick, etc. Each of the tool attachments is in effect an unassembled tool.

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 essential character is imparted by the mattock, pick attachments, rake and hoe, which are all classified under the identical tariff classification. The U.S. made axe sheath and the canvas bag are classified as American Goods Returned in 9801.00.1082 and are duty free. The "Max" tool set is packaged in a sealed individual carton and sold as such to the end user.

The applicable subheading for the "Max" tool will be 8201.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for mattocks, picks, hoes and rakes, and parts thereof... The duty rate will be 2.9% ad valorem.

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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