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NY N007029

March 7, 2007



TARIFF NO.: 8302.49.4000

Mr. Roy Gilbert
RG PetComm LLC
9355-A Lake Murray Blvd.
San Diego, CA 92119

RE: The tariff classification of a pet leash accessory from Mexico or China

Dear Mr. Gilbert:

In your letter dated February 9, 2007, you requested a tariff classification ruling.

The sample you submitted is an article called the “SmartWalk Manager.” It is made of a solid, rectangular shaped, aluminum tube with a spring-loaded gate and foam handle, called the “leash retainer;” a lambskin leather pouch that fits around and adheres to the leash retainer with velcro; and a steel, swivel snap hook. It will be imported fully assembled and packaged in a plastic clamshell, ready for retail sale. It comes in two sizes, large and small.

The leash retainer attaches to the handles of dog leashes and enables a dog walker to secure and hold multiple leashes with one hand. The lambskin pouch attaches to the leash retainer and is used to hold unused cleanup bags, treats, keys, wallet, etc. The snap hook attaches to the leash retainer and is used when only one or two leashes are employed.

Your letter indicates that you believe the leash retainer and pouch should be classified separately as follows: leash retainer in subheading 7616.99.5075, HTSUS, as other articles of aluminum; and leather pouch in subheading 4202.91.0030, HTSUS, as travel, sport and similar bags with outer surface of leather. This office, however, disagrees. The SmartWalk Manager is comprised of components from three different headings in the tariff: the leash retainer, which is most specifically described in subheading 8302.49.40, HTSUS, as mountings and fittings suitable for saddlery; the leather pouch, which is classified in subheading 4202.91.00, HTSUS; and the steel snap hook, which is classified in subheading 7326.90.85, HTSUS. Since it is made up of separable components that are adapted to one another and are put up in common packing, the SmartWalk Manager fits the description of a composite good as defined in Explanatory Note (EN), Rule 3(b)(IX). As such, the SmartWalk Manager is classified according to the component that gives its essential character. The essential character of this product is determined to be imparted by the rectangular shaped, aluminum tube, which serves to join and hold the various leashes together and act as a handle for the dog walker.

The applicable subheading for the SmartWalk Manager will be 8302.49.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articlesother mountings, fittings and similar articles, and parts thereof, other, harness and saddlery or riding-bridle hardware, and parts thereof, other. The rate of duty will be free.

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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