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NY L87687




October 4, 2005

CLA-2-73:RR:NC:N1:113: L87687

CATEGORY: CLASSIFICATION

TARIFF NO.: 7326.90.8587; 7616.99.5090; 8513.10.2000

Ms. Barbara Clausen
FedEx Trade Networks
205 West Service Road
Champlain, NY 12919

RE: The tariff classification of luggage tags, key rings, and a flashlight from China and Taiwan

Dear Ms. Clausen:

In your letter dated September 13, 2005, on behalf of Banker Pen, you requested a tariff classification ruling.

The samples you submitted are two luggage tags (item numbers G509 and G518), two key rings (item numbers G830 and G808), and a flashlight (item number FL25).

Item number G509 is a luggage tag made of steel with a leather strap. In your letter, you state the tag is made of a zinc alloy. However, since the tag attracts a magnet, it is likely made of steel rather than a zinc alloy. The luggage tag measures approximately 3.5 inches long by 1.5 inches wide. There is a preprinted paper insert inside for writing a name, address and telephone number. The country of origin is China.

The applicable subheading for the steel luggage tag (G509) will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

Item number G518 is a luggage tag made of aluminum with a stainless steel wire attached. The wire has a screw closure for securing the tag to luggage. The tag measures approximately 4 inches long by 2.25 inches wide. It can accommodate a business card. The aluminum component of the luggage tag predominates by weight. The country of origin is China.

The applicable subheading for the aluminum luggage tag (G518) will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of aluminum, other, other, other, other, other, other. The rate of duty will be 2.5 percent ad valorem.

Item number FL-25 is called the LED keylite. It is composed of a small LED flashlight attached to a steel wire split ring by a short chain. The flashlight is encased in plastic and activated by squeezing. The illumination produced by the mini flashlight projects away from the key ring. The essential character of this composite good is imparted by the mini flashlight. The country of origin is Taiwan.

The applicable subheading for the flashlight/key ring 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 energylamps, flashlights. The rate of duty will be 12.5 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on item G830, the detachable tube key ring or item G808, the tire key ring. Your request for a classification ruling should include a breakdown by weight of the various metals in both articles. For G830, that would be the weight of the brass versus the weight of the iron. For G808, that would be the weight of the iron versus the weight of whatever metal is inside the mini rubber tire. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,

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