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NY F81404

January 21, 2000

CLA-2-39:RR:NC:SP:221 F81404


TARIFF NO.: 3926.90.9880

Mr. R. Kevin Williams
O’Donnell & Williams
20 North Wacker Drive
Suite 1416
Chicago, Illinois 60606

RE: The tariff classification of “EZ Light” clips and hooks from China.

Dear Mr. Williams:

In your letter dated December 23, 1999, on behalf of Santa’s Best, you requested a tariff classification ruling.

Samples were provided with your letter. The merchandise consists of three types of plastic clips and hooks: EZ Light Gutter Hooks, EZ Light Universal Icicle Light Clips and EZ Light Universal Multi-Position Light Clips. These hooks and clips are used to attach Christmas lights to the gutters and shingles of a house. The fasteners either slide under the shingles or clip onto the gutters. The are not permanently attached to the building. The light strings either slide or snap into the fasteners for temporary installation. They are not permanently attached to the hooks or clips. The samples are being returned as you requested.

You have suggested classification in subheading 9405.92.00, HTS, which provides for lamps and lighting fittings including searchlights and spotlights and parts thereof. However, the EZ Light clips and hooks are not classified as parts because they are not integral, constituent, or components parts, without which the lights could not function.

The applicable subheading for the EZ Light hooks and clips will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of plastics, other. The rate of duty will be 5.3 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 Joan Mazzola at 212-637-7034.


Robert B. Swierupski

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