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NY J87960

August 26, 2003

CLA-2-82:RR:NC:1:104 J87960


TARIFF NO.: 8207.50.6000

Mr. Arthur G. Briggs
Dominion Customs Consultants Inc.
1220 Sheppard Avenue East, Suite 400
Willowdale, Ontario, Canada M2K 2S5

RE: The tariff classification of a lock installation kit from China

Dear Mr. Briggs:

In your letter dated August 1, 2003 on behalf of Maxtech Consumer Products Group of Waterloo, Ontario you requested a tariff classification ruling.

You indicate that the Home Depot Lock Installation Kit consists of the following:

1. 1 inch spade bit
2. 2 1/8 inch carbon hole saw
3. mandrel (also called arbor)
4. plastic & metal template
5. center punch nail set

You have provided a picture of the kit as packaged for retail sale. Per discussion with Maxtech’s operations manager Mr. Subhash on August 26, 2003, the mandrel includes a pilot drill bit and the spade bit is made of carbon steel.

You suggest that classification should be under subheading 8207.50.6000 noting HQ ruling 963775 of November 21, 2000 and NY rulings H80305 of May 23, 2001 and J82340 of March 25, 2003. These rulings classified lock installation kits as GRI 3(c) sets. Since the spade bit is made of carbon steel, 8207.50.6000 becomes the subheading which occurs last in numerical order amongst those headings that merit equal consideration.

The applicable subheading for the Home Depot Lock Installation Kit will be 8207.50.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for interchangeable tools for handtools, whether or not power operated : tools for drilling, other than rock drilling: other: not suitable for cutting metal: for handtools. The rate of duty will be 5.2 percent.

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 Robert Losche at 646-733-3011.


Robert B. Swierupski

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