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NY N006151

February 22, 2007



TARIFF NO.: 8204.11.0060

Ms. Kim Lamberton
Norman G. Jensen, Inc.
102 West Service Road
Champlain, NY 12919

RE: The tariff classification of hex key sets from China.

Dear Ms. Lamberton:

In your letter dated January 25, 2007, on behalf of RUI Royal International, Corp., Plattsburgh, NY, you requested a tariff classification ruling.

The submitted samples are a 30-piece Hex Key Set (item #7330), one piece of a 10-piece Hex Key Set (item #7340) and a 9-piece SAE Hex Key Set (item #D781 4151 8523). The hex keys within the 30-piece hex key set are made of chrome vanadium steel and are fully hardened and tempered. Each hex key has its own fitted compartment within the plastic case. One T-handle hex key was sent to represent the 10-piece hex key set. The handle is non-metallic and the key is chrome vanadium. The hex keys in the 9 piece hex key set are made of chrome molybdenum steel and are housed in a non-metallic handle. Each key folds out for use.

The applicable subheading for the hex key sets will be 8204.11.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives and extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: nonadjustable, and parts thereof: other (including parts). The rate of duty will be 9% ad valorem.

Consideration was given to classifying your items under 8205.40.0000, HTSUS, as you suggested, however, that classification was deemed inappropriate. The above referenced items are recognized as wrenches in the industry. The exerted twisting force applied to the handles of these tools is generally perpendicular to the main axis of the fastener. This action is similar to that of other wrenches, not screwdrivers.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Kathy Campanelli at 646-733-3021.


Robert B. Swierupski

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