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NY N008294

March 19, 2007



TARIFF NO.: 8301.40.6030

Mr. Denis Emond
519 Cure-Boivin
Boisbriand, Quebec
Canada J7G 2AB

RE: The tariff classification of an electronic lock mechanism from Canada

Dear Mr. Emond:

In your letter received on March 14, 2007, you requested a tariff classification ruling.

The sample you submitted, which will be returned to you, called the “RetroFit 1000,” is described as an electronic combination chamber. It is a replacement part that retrofits inside the housing of a mechanical lock. By replacing the mechanical combination chamber of a pushbutton lock with the RetroFit 1000 combination chamber, a pushbutton mechanical lock is converted into a multifunction, electronic access control lock. It is used on mechanical locks located on interior and exterior conventional doors. You indicate that its locking components, which include a mounting plate, top and bottom cam, stud (linkage shaft), and DC solenoid are made of base metal.

The RetroFit 1000 includes the locking mechanism and as such, it imparts the essential character to the complete or finished lock. Accordingly, the RetroFit 1000 is classified as an incomplete lock per GRI 2(a).

The applicable subheading for the electronic locking mechanism will be 8301.40.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for padlocks and locks (key, combination or electrically operated), of base metalother locks, other, door locks, locksets and other locks suitable for use with interior or exterior doors (except garage, overhead or sliding doors). The rate of duty will be 5.7 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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