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July 30, 1999

CLA-2-96:RR:NC:N1:113 E84868


TARIFF NO.: 9608.99.4000; 9608.99.0060; 7320.20.5020

Brigadier General Philip H. Pushkin
WoodWrite, Ltd.
2121 Abeil Lane
Sparks, Maryland 21152

RE: The tariff classification of pen parts from Taiwan

Dear Brigadier General Pushkin:

In your letter dated July 19, 1999, you requested a tariff classification ruling.

The samples you provided are of various parts of pens and mechanical clutch pencils. The parts will be imported in bulk from Taiwan. Your company packages the parts together and sells them as individual kits for customers who craft wooden pen or pencil barrels. The parts include the brass support tubes, end caps, clips, brass ferrules, decorative rings, inserts, point assemblies, gold end caps, ball point ink cartridges and springs. Some of these parts may be used on both the pens and clutch pencils, and some are unique to either.

The applicable subheading for the springs, which we presume are of steel, will be 7320.20.5020, Harmonized Tariff Schedule of the United States (HTS), which provides for springs and leaves for springs, of iron or steel, helical springs, other, helical springs, of wire having a cross-sectional dimension of less than 5.1 mm, other. The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for those parts which are exclusively designed for pens will be 9608.99.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of articles provided for in subheadings 9608.10 [ball point pens], 9608.31 and 9608.30 [fountain pens, stylograph pens and other pens]. The rate of duty will be free.

The applicable subheading for the remaining parts will be 9608.99.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts [of propelling or sliding pencils], other. The rate of duty will be free.

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 James Smyth at 212-637-7008.


Robert B. Swierupski

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