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NY N018967

November 1, 2007



TARIFF NO.: 8205.59.5510

Mr. Joseph Delahanty
Panalpina Inc.
1776 On-The-Green
67 Park Place
Morristown, NJ 07960

RE: The tariff classification of a razor blade scraper from China.

Dear Mr. Delahanty:

In your letter dated October 23, 2007, on behalf of your client, Delta Carbona, L.P., you requested a tariff classification ruling. The sample which you submitted is being returned as you requested.

The item is described as a Carbona Cooktop Scraper. It is used to clean glass ceramic cooktops by scraping. The scraper handle is plastic and holds a single retractable steel razor blade that operates with a sliding thumb control. The scraper also includes three replacement blades which are stored within the tool handle.

The applicable subheading for the razor scraper will be 8205.59.5510, Harmonized Tariff Schedule of the United States (HTSUS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other: other: other: of iron or steel: other: edged handtools: other. The rate of duty will be 5.3% ad valorem.

Consideration was given to the suggested classification of subheading 8212.10.00, HTSUS, which provides for razors. In understanding the language of the HTSUS, the Harmonized Commodity Description and Coding System Explanatory Notes may be utilized. The Explanatory Notes (ENs), although not dispositive nor legally binding, provide a commentary on the scope of each heading of the HTSUS, and are the official interpretation of the Harmonized System at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). Examples of tools noted within the ENs that are classified within heading 8205 are scrapers and stripping knives. The cooktop razor scraper is a hand tool found within heading 8205. The razors and razor blades noted within heading 8212 are intended for hair removal.

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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