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NY N026336

April 29, 2008



TARIFF NO.: 8205.59.5560

Ms. Debbie Bell
Compliance Coordinator
Bealls Imports Inc.
1806 38th Avenue East
Bradenton, FL 34208

RE: The tariff classification of an auto escape key chain from China.

Dear Ms. Bell:

In your letter dated April 8, 2008, you requested a tariff classification ruling. The sample which you submitted is being returned as requested.

The auto escape key chain (style# PS1237XX) is described as a multi-tool key chain. You state that its main function is to aid in the escape from a vehicle in a minor emergency situation. In the event of an emergency, the multi-tool can be detached from the key ring. If car doors or windows are stuck, the tool can be used to shatter glass by pressing the encased spring loaded steel tip against a car window. In addition, the shielded metal blade can be used to cut through jammed seat belts.

The applicable subheading for the auto escape key chain will be 8205.59.5560, 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: other (including parts). The rate of duty will be 5.3% ad valorem

Consideration was given to your proposed classification of 8708.99.81, HTSUS. However, this multi-purpose tool does not add to the convenience or effectiveness of a motor vehicle, rather it has uses beyond that of an automotive accessory. Therefore, it would not be classifiable in subheading 8708.99.81 or in Chapter 87 at all.

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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