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NY J88505

September 29, 2003

CLA-2-85:RR:NC:2:227 J88505


TARIFF NO.: 8513.10.2000

Mr. Steve Enderson
W.J. Byrnes & Co.
880 Mitten Rd., Ste. C
Burlingame, CA 94010

RE: The tariff classification of a flashlight and key ring combination from China.

Dear Mr. Enderson:

In your letter dated August 28, 2003, on behalf of Royal Robbins, Inc., you requested a tariff classification ruling.

The submitted sample, referred to as the “carabiner,” is a metal (aluminum) composite article that features a flashlight incorporated along the full-length of a D-shaped snap ring. This ring has a clip for securing metal split-key rings.

You state that this article is properly classified under subheading 7616.99.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of aluminum, otherother, other. This claim is supported in noting that the subject article primarily functions as a key holder with the flashlight serving the ancillary role to illuminate the lock for inserting the key.

This office, however, finds that both the flashlight and key holder function equally in their specific roles. Therefore, since no one component of this composite article imparts the essential character, this merchandise will be classified, with respect to the General Rule of Interpretation 3©, under the heading (8513, HTS) which occurs last in numerical order among those which equally merit consideration. The applicable subheading for the flashlight and key ring combination will be 8513.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for portable electric lamps designed to function by their own source of energy...lamps: flashlights. The rate of duty will be 12.5 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 George Kalkines at 646-733-3028.


Robert B. Swierupski

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