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NY N014163

July 20, 2007



TARIFF NO.: 6914.90.8000: 6914.10.8000

Mr. John Higinbothom
Amerock Corporation
6350 Stevens Forest Road, Suite 200
Columbia, MD 21046

RE: The tariff classification of cabinet hardware from China and Hong Kong.

Dear Mr. Higinbothom:

In your letter dated July 2, 2007, you requested a tariff classification ruling.

The submitted samples consist of five styles of knobs and pulls that are designed for installation on kitchen cabinets.

Item Number BP76246-W3 is a round, white, ceramic knob that measures 1¼ inches in diameter, with a zinc base and cap.

Item Number BP76243-WB is a pull that measures 5 inches with a 2½ inch ceramic center with zinc ends.

Item Number BP76242-26W is a pull that measures 5 inches with a 2 5/8 inch ceramic center with zinc ends.

Item Number BP76245-WB is a pull that measures 5 ¼ inches with a 1½ inch ceramic center with zinc ends.

Item Number 69128 is a round, white, porcelain knob that measures 1½ inches in diameter, decorated with flowers.

The pulls are made from solid pieces of ceramic with zinc ends. The zinc ends are inserted into the ceramic pieces in pre-drilled holes. You indicated that an exact breakdown of the component values is not available, but in your opinion the zinc comprises the majority of the products’ total value. In addition, you indicated that the zinc would be the heavier of the two knob components, and in most, if not all cases, the same would hold true for the pulls.

The subject knobs and pulls are composed of different components and are considered composite goods. Regarding the essential character of the knobs and pulls, the Explanatory Notes to GRI 3 (b) (VIII) state that the factor which determines essential character will vary between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the part that imparts the essential character to the composite good. In each case of the subject merchandise, the ceramic portion imparts the essential character to the good.      

The applicable subheading for the ceramic knob, Item Number BP76246-W3, and the ceramic and zinc pulls, Item Numbers BP76243-WB, BP76242-26W, and BP76245-WB, will be 6914.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other ceramic articles: Other: Other.” The rate of duty will be 5.6% ad valorem.

The applicable subheading for the porcelain knob, Item Number 69128, will be 6914.10.8000, HTSUS, which provides for “Other ceramic articles: Of porcelain or china: Other.” The rate of duty will be 9% 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 Sharon Chung at 646-733-3028.


Robert B. Swierupski

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