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NY N014137

August 13, 2007



TARIFF NO.: 4420.90.8000

Mr. Kenneth Charnley
Liberty International, Inc.
470 Main Street
Pawtucket, RI 02860

RE: The tariff classification of a wooden valet from China

Dear Mr. Charnley:

In your letter dated July 10, 2007, on behalf of Swank Inc., you requested a tariff classification ruling.

The ruling was requested on a men’s wooden desk valet box and a men’s wooden valet, both containing a wallet and other items. A prototype sample of the wooden valet containing a wallet and a key chain was submitted for our review, which will be returned to you.

The sample valet is an open rectangular container measuring approximately 7-3/4” long x 5” wide x 1-1/8” high. It is constructed of sturdy 3/8” thick wood with a coated reddish-brown finish. The exterior surfaces of the sides of the container are decoratively grooved. The interior bottom is lined with a flocked material. Packed inside the valet is a removable fitted packaging insert containing a wallet and a metal key chain. The prototype sample additionally has a small metal plaque with a designer’s name attached on one side; however, you state that the valet container to be imported will not include this plaque.

Although the valet, wallet and key chain will be imported packed together for retail sale, they are not considered to be a set for classification purposes and will be classified separately. Each of the articles has a separate function; they are not intended to be used together. Further, the valet is not merely packing for the wallet and key chain. It is a container designed to be placed on a desk or dresser and used to keep small personal items together for ready access.

The applicable subheading for the wooden valet will be 4420.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for wooden articles of furniture not falling within chapter 94. The rate of duty will be 3.2 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/.

Your inquiry does not provide enough information to give a classification ruling for the wallet, for the key chain or for the wooden desk valet box containing a wallet and a card case. Your request for a classification for these products should include a sample of the desk valet box with its contents in the condition it will be imported in, identification of the lining material (the flocked fibers and the material underneath), identification of the material that the wallets and card cases are constructed of (e.g., leather, plastic sheeting, etc.), and a breakdown by weight of the component metals comprising the key chain. When this information is available you may wish to resubmit your request for a ruling for these products. Please include a copy of this letter with your resubmission.

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 Paul Garretto at 646-733-3035.


Robert B. Swierupski

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