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February 26, 1999

CLA-2-96:RR:NC:SP:233 D88531


TARIFF NO.: 9603.90.8050

Ms. Karen MacGillivray
Tower Group International, Inc.
128 Dearborn Street
Buffalo, NY 14207-3198

RE: The tariff classification of a window film tool kit from China.

Dear Ms. MacGillivray:

In your letter dated February 22, 1999, on behalf of Axius Autoshade, you requested a tariff classification ruling.

The submitted sample is the “Window Film Tool Kit.” It is used to assist in applying window film. The product consists of a 4" black rubber squeegee and a plastic and metal utility knife. The squeegee has a straight edge and an angled edge to apply tint in hard to reach window contours. The utility knife has a razor blade edge that can be broken off to provide a sharp new blade. There are 12 break off blades in the utility knife. The razor can be used to clean windows before application or used as an alternative for cutting tint to the desired shape. The squeegee and utility knife are packaged together for retail sale in a blister pack.

We find that the above?described items comprise, for tariff purposes, "goods put up in sets for retail sale." With reference to General Rule of Interpretation ("GRI") 3(c), Harmonized Tariff Schedule of the United States (HTS), we find that the squeegee (heading 9603) and the utility knife (heading 8211) equally merit consideration in determining the classification of the set, but that neither of those components alone can be said to impart the essential character of the whole. Under such circumstances, GRI 3(c) directs that the set be classified under the heading which occurs last in numerical order. Accordingly, the applicable subheading for window film tool kit will be 9603.90.8050, Harmonized Tariff Schedule of the United States (HTS), which provides for brooms, brushes,... squeegees. The rate of duty will be 2.8 percent ad valorem.

This ruling is being issued under the provisions of Part 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 Lawrence Mushinske at 212-637-7061.


Robert B. Swierupski

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