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NY N006664

February 23, 2007



TARIFF NO.: 8205.20.6000

Mr. Mel Speizer
Mel Speizer Consultants, Inc.
3075 Windsor Place
Boca Raton, FL 33434

RE: The tariff classification of sledge hammers from Vietnam.

Dear Mr. Speizer:

In your letter dated February 6, 2007, you requested a tariff classification ruling.

You have stated that various sizes of long steel bars will be shipped from China to Vietnam. The solid steel bars will not have the shape or size of a sledge hammer head. After receipt in Vietnam, the long steel bars will be cut into the sizes needed for the manufacturing process. The cut bars are then heat-treated, drop forged and further worked into sledge hammer heads. The sledge hammer heads will range in size from 4lbs to 10lbs. The imported item numbers are as follows: SSI-4LB, SDI-4LB, SH-8LB, SSI-8LB, SDI-8LB, SSI-10LB, and SDI-10LB.

The applicable subheading for the sledge hammers will be 8205.20.6000, Harmonized Tariff Schedule of the United States (HTSUS), 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: hammers and sledge hammers, and parts thereof: with heads over 1.5 kg each. The rate of duty will free.

You also requested clarification on the country of origin of the sledge hammers. Although the raw material will be supplied from China, you state that the manufacturing processing will be done in Vietnam. Accordingly, the country of origin of the finished sledge hammers will be Vietnam.

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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