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NY 812168

July 6, 1995

CLA-2-73:S:N:N3:115 812168


TARIFF NO.: 7326.20.0050

Ms. Tracy Ann Ehme
AW Fenton
P.O. Box 360614
Columbus, Ohio 43236-0614

RE: The tariff classification of a keychain from the Dominican Republic.

Dear Ms. Ehme:

In your letter dated June 22, 1995, you requested a tariff classification ruling, on behalf of your client, Rocky Shoes & Boots Co., Nelsonville, OH. Your submitted sample will be returned to you as requested.
The subject item is a keychain made of steel which is attached to a decorative piece of leather. The leather is of U.S. origin which is sent to the Dominican Republic to be cut, embossed and attached to the steel ring.

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 steel ring imparts the essential character.

The applicable subheading for the keychain will be 7326.20.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel wire, other. The duty rate will be 5.3% ad valorem.

Articles classifiable under subheading 7326.20.0050, HTS, which are products of the Dominican Republic, are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

Consideration was given to classifying this product under subheading 7326.90.8590 and 9802.00.5060, HTS, as you have suggested. However, the article is made of steel wire thereby rendering 7326.90.8590 inappropriate. 9802.00.5060 applies to articles sent to another country for repairs or alterations to completed articles. The leather attachment when sent to the Dominican Republic is not a completed article and must be subjected to operations that make it a product of that country. Being that the item is eligible for GSP under subheading 7326.20.0050, the issue appears moot.

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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