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NY N015002

August 13, 2007



TARIFF NO.: 8206.00.0000; 8204.20.0000

Mr. Artem Kalajyan
Director, Legal
Olympia Tools International, Inc.
18051 Arenth Avenue
City of Industry, CA 91748

RE: The tariff classification of a 95-Piece Tool Set from China.

Dear Mr. Kalajyan:

In your letter dated July 30, 2007, you requested a tariff classification ruling.

You describe a 95-piece tool set housed in a blow molded case which contains the following items: One ratcheting handle
One flexible extension adapter
One adapter
One steel magnetic parts tray
Six jeweler’s (precision) screwdrivers in a fitted plastic case Twenty-four sockets
Sixty screwdriver bits
One picture hanging kit in a small plastic case which includes five carbon steel picture hanging hooks, twenty-four carbon steel 5/16” nails, five carbon steel 5/16” screws and five plastic wall fastening plugs

The applicable subheading for the 95 piece tool set will be 8206.00.0000, Harmonized Tariff Schedule (HTSUS), which provides for tools of two or more of the headings of 8202 to 8205, put up in sets for retail sale. Heading 8206 requires that duty be applied to that article in the set subject to the highest rate of duty. The articles in this set subject to the highest rate of duty are the sockets, classifiable in subheading 8204.20.0000, which provides for hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives and extensions; base metal parts thereof: socket wrenches, with or without handles, drives and extensions, and parts thereof. The duty rate will be 9% ad valorem. The complete tariff classification of the set will be 8206.20.0000/8204.20.0000, HTSUS.

Consideration was given to your proposed tariff classification of 8466.10.0175, HTSUS, however, that classification was deemed inappropriate. Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. Inasmuch as the item is classifiable within heading 8206 pursuant to GRI 1, there is no need to do a GRI 3 analysis.

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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