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NY D84982

December 1, 1998



TARIFF NO.: 8211.93.0030

Mr. Arlen T. Epstein
Tompkins & Davidson
1515 Broadway
New York, N.Y. 10036-8901

RE: The tariff classification of a Golfer's Pocket Tool from China.

Dear Mr. Epstein:

In your letter dated November 24, 1998 you requested a tariff classification ruling on behalf of your client Avon Products.

The sample submitted is a metal multi-purpose tool (style PP 185916). The article, measuring approximately 3 1/4 inches in length is constructed of steel and incorporates the following components: a knife, a bottle opener, golf club groove cleaner, a cleat tightener and golf ball mark repairer. A metal split key ring is attached to one end of the item by a metal link chain. The sample is being returned to you as per your request.

The instant merchandise comprises a composite article with various components. As each of the components contribute equally to the use of the article, classification is determined by reference to the General Rules of Interpretation 3(c), which provides for the classification under the heading which is last among those which equally merit consideration. In this sample the knife appears last among the items under consideration.

The applicable subheading for the multi-purpose tool will be 8211.93.0030, Harmonized Tariff Schedule of the United States (HTS) which provides for Knives having other than fixed blades...Pen knives, pocket knives and other knives which have folding lades. The rate of duty will be 3 cents each + 5.4% ad valorem.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Melvyn Birnbaum at 212-466-5487.


Robert B. Swierupski
National Commodity

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