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NY E86600

September 2, 1999

CLA-2-73:RR:NC:1:118 E86600


TARIFF NO.: 7312.10.5000

Mr. Robert Schlipper
Outpac Designs Limited
GPO Box 11464
Folcroft West Business Park
Hong Kong

RE: The tariff classification of an adjustable wire locking device from China.

Dear Mr. Schlipper:

In your letter dated August 20, 1999, you requested a tariff classification ruling. A sample was enclosed with your inquiry.

You stated that the subject item is an adjustable wire locking device. It is comprised of a 3mm diameter 7 x 19 stranded stainless steel cord looped at one end, polycarbonate beads and a polycarbonate locking device affixed at the other end. The wire locking device will be imported without a padlock. The primary function of the item is to secure luggage.

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 stranded stainless steel cord imparts the essential character. The applicable subheading for the adjustable wire locking device will be 7312.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated; stranded wire, ropes and cables: ropes, cables and cordage other than stranded wire: of stainless steel: fitted with fittings or made up into articles. The duty rate will be 2.8% 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 this 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 Kathy Campanelli at 212-637-7025.


Robert B. Swierupski

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