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NY N006408

February 12, 2007



TARIFF NO.: 8309.90.0000; 3923.50.0000

Mr. Timothy J. Ruane
Illinois Tool Works Inc.
3600 W. Lake Avenue
Glenview, IL 60026

RE: The tariff classification of seals from England and China

Dear Mr. Ruane:

In your letter dated January 24, 2007, you requested a tariff classification ruling. The samples you submitted are five types of security, indicative and/or barrier seals.

The “Snapper” is described as a “high security plastic coated metal bolt seal.” The bolt and body are made of plastic coated steel. It is used to secure vehicle doors and shipping containers.

The “Metflex” is described as a “high strength metal bodied cable seal with plastic cover.” Its body, locking mechanism and cable are made of steel. It comes with either a 1.6 mm cable or a 2.5 mm cable. It is used to secure freight containers, vehicle doors, tankers, airline trolleys and roll cages.

The “Padflex” is described as a “plastic bodied cable seal with 1.5 or 2.5 mm steel cable.” It is an indicative seal that also offers barrier protection since it can only be removed with tools. It is used to secure airline trolleys, freight containers, tankers, roll cages and vehicle doors.

The “Aria & Duoseal” is described as a “ keyless padlock secured by indicative seal.” It has a body made of glass filled nylon (the Aria), a stainless steel shackle, an ABS plastic device (the Duoseal), and a chrome plated brass chain with split ring. It is secured by pressing the Duoseal into the recess in the body. It is reusable, although a new Duoseal must be applied whenever the seal is to be reused. It is used to secure airline trolleys, roll cages, airfreight containers, vehicle doors and curtain sided lorries.

The “Padseal Minor” is described as a “re-useable combined indicative or barrier seal.” It has a reusable, glass filled nylon body, a chrome-plated brass chain with split ring, and either a plastic or a metal shackle. When used with the plastic shackle it acts as an indicative seal, when used with the metal shackle it acts as a barrier seal. It is used to secure airline trolleys, roll cages, vehicle doors, curtain sided lorries and airfreight containers.

The applicable subheading for the “Snapper” and the “Metflex” seals will be 8309.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for stoppers, caps and lidsseals and other packing accessories, and parts thereof, of base metal, other. The rate of duty will be 2.6 percent ad valorem.

The applicable subheading for the “Aria & Duoseal,” “Padflex” and “Padseal Minor” seals will be 3923.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures of plastics, stoppers, lids, caps and other closures. The rate of duty will be 5.3 percent ad valorem.

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 Barbara Kaiser at 646-733-3024.


Robert B. Swierupski

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