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NY 806175

January 27, 1995

CLA-2-82:S:N:N3:115 806175


TARIFF NO.: 8205.59.5560

Mr. David A. Eisen
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway
43rd Floor
New York, New York 10036-8901

RE: The tariff classification of a multi-purpose tool from China and/or Taiwan.

Dear Mr. Eisen:

In your letter dated January 20, 1995, you requested a tariff classification ruling, on behalf of your client, Avon Products Inc., NY, NY. Your submitted sample will be returned to you as requested.

The submitted sample is a steel metal multi-purpose tool which will be imported and sold in a vinyl carrying case. The article, measuring approximately 3" in length in the closed position, is constructed of steel, a rigid plastic handle and safety cover and incorporates the following components: can opener, 4 position wrench edge, butterfly screw wrench edge, magnifying lens, key chain hole, fork, direction auxiliary indication, and ruler.

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 handtool applications impart the essential character.

The applicable subheading for the multi-purpose tool will be 8205.59.5560, Harmonized Tariff Schedule of the United States (HTS), which provides for other handtools not elsewhere specified or included; base metal parts thereof...of iron or steel: other. The duty rate will be 5.3% 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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