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NY R02609

October 18, 2005

CLA-2-82:RR:NC:N1:118 R02609


TARIFF NO.: 8205.51.6000

Ms. Lori Jo Boullet
Columbia Sportswear Company
14375 Northwest Science Park Drive
Portland, OR 97229

RE: The tariff classification of a bottle opener on a key ring from China.

Dear Ms. Boullet:

In your letter, dated September 23, 2005, you requested a tariff classification ruling.

Style ZC1009 is an aluminum bottle opener on a steel wire split key ring. The aluminum bottle opener is in the shape of a ski.

The applicable subheading for the bottle opener on the key ring will be 8205.51.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: household tools, and parts thereof: of aluminum. The rate of duty will be 2.2¢ per kg, plus 5% ad valorem.

Consideration was given to classification in subheading 7326.20.0070, HTS, as you had suggested. However, since the attachment to the split ring is a functional article, the item would be classified as the attachment, rather than as the less specific split ring (article of metal). We have also given consideration to classification in subheading 8205.59.5560, HTS, as you had suggested. However, “household toolsof aluminum” more specifically describes the bottle opener.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR).

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 Kathy Campanelli at 646-733-3021.


Robert B. Swierupski

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