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NY N021118

December 28, 2007



TARIFF NO.: 8205.51.3030

Ms. Mary F. Boehlert
BIC Corporation
500 BIC Drive
Milford, CT 06460

RE: The tariff classification of metal key rings with attached bottle openers from Mexico.

Dear Ms. Boehlert:

In your letter dated December 14 2007, on behalf of BIC USA Inc., Tampa FL, you requested a tariff classification ruling. The samples which you submitted are being returned as requested.

The four submitted samples are each a steel ring attached to a piece of shaped carbon steel by a metallic shackle. The carbon steel attachment is shaped into a functional bottle opener. You state that each attachment is plated with powered epoxy polyester black paint over carbon steel and is approximately 2 ½” in length. Each functional bottle opener attachment contains a clear plastic dome emblem with a custom logo underneath the emblem. The custom plastic emblem is for decorative purposes only. The four samples are identified by the following style numbers: KMB150, KMB151, KMB152 and KMB250.

The applicable subheading for the metal key rings with attached bottle openers will be 8205.51.3030, 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: household tools, and parts thereof: of iron or steel: other (including parts): kitchen and table implements. The general rate of duty will be 3.7% 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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