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March 10, 1999

CLA-2-82:RR:NC:115 D88859


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 multi-purpose pocketknife with an attached split-key ring and chain from China.

Dear Mr. Epstein;

In your letter dated March 4, 1999 you requested a tariff classification ruling on behalf of your client Avon Products, Inc.

The sample submitted (PP189635) is a multi-purpose pocketknife with an attached split-key ring and chain. The pocketknife incorporates the following components: a stainless steel knife blade, a metal implement with screwdriver tip, pair of scissors and a nail file. A metal split key ring is attached to one end of the pocketknife by a metal link chain.

The instant merchandise comprises a composite article with various components. The headings at issue refer to part only of the materials or substances contained in the composite good, and according to GRI 3(a) are to be regarded as equally specific, thereby making resort to GRI 3(b) necessary. As each of the components contribute equally to the use of the article, classification is determined by reference to GRI 3(c), which provides for the classification under the heading which is last among those which equally merit consideration. Accordingly, the multi-functional pocket is classifiable as a pocket knife within subheading 8211.93.0030.

The applicable subheading for the multi-purpose knife with key ring attached will be 8211.93.0030, Harmonized Tariff Schedule of the United States (HTS), which provides for Other: Knives having other than fixed blades: Pen knives, pocket knives and other knives which have folding blades. The rate of duty will be 3 cents each + 5.4% 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 Melvyn Birnbaum at 212-637-7017.


Robert B. Swierupski

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