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NY N019267

November 13, 2007



TARIFF NO.: 8203.20.6030

Ms. Dana Antoine
Customs Administration
Carmichael International Service
533 Glendale Blvd.
Los Angeles, CA 90026-5097

RE: The tariff classification of an eyelet pliers/hole punch with eyelets from China.

Dear Ms. Antoine:

In your letter dated October 30, 2007, on behalf of your client, Alltrade Tools LLC, you requested a tariff classification ruling. The sample which you submitted is being retained by this office.

You have described the item, number SVP0102, as a blister pack containing an eyelet pliers/hole punch with brass plated aluminum eyelets. The packaging is labeled “eyelet pliers w/100 eyelets.” A hole is punched in the material with the hole punch feature then an eyelet is inserted and the pliers is used to crimp the eyelet in place. The working edges of the tool are made of carbon steel.

The tool with the eyelets is a set put up for retail sale. The tool is a composite good. The hole punch prepares a hole for the eyelet which the eyelet pliers secures in place. The role of this tool as an eyelet setter provides the essential character.

The applicable subheading for the eyelet pliers/hole punch with metal eyelets will be 8203.20.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: pliers (including cutting pliers), pincers, tweezers and similar tools, and parts thereof: other: other (except parts), pliers. The rate of duty will be 12¢/doz. + 5.5% 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 Kathy Campanelli at 646-733-3021.


Robert B. Swierupski

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