The tariff classification of tool kits from Taiwan

NY H80677 May 15, 2001 CLA-2-82:RR:NC:1:104 H80677 CATEGORY: Classification TARIFF NO.: 8207.90.6000; 8205.40.0000; 8466.10.8075 Ms. Nancy Jin Peace International Corporation 831 Foster Avenue Bensenville, Illinois 60106 RE: The tariff classification of tool kits from Taiwan Dear Ms. Jin: In your letter dated April 25, 2001 on behalf of Hand Tools International of Lake Zurich, Illinois you requested a tariff classification ruling. Two samples have been provided of tool kits in textile tool rolls. The samples will be returned as requested. The first sample includes 4 screwdriver bits, a screwdriver handle and an extension adapter. The tool roll has pockets for the screwdriver handle and the adapter and a hard plastic strip riveted at each end to the inside of the roll. Four hard plastic sliders with posts are attached to this strip. The bits, which are mounted in a socket type holder, fit snugly over the posts for storage. The second sample includes 10 screwdriver bits (no handle or adapter). It has two hard plastic strips riveted to the roll, each with five sliding posts for the bits. You indicate that the kits will not be imported in retail packaging hence they cannot be considered as sets for tariff purposes. The textile tool rolls are not generic tool rolls. The applicable subheading for the first sample will be 8205.40.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for screwdrivers and parts thereof. The rate of duty will be 6.2 percent. The applicable subheading for the second sample will be 8207.90.6000, HTS, which provides for other interchangeable tools: other: other: not suitable for cutting metal: for handtools. The rate of duty will be 4.3 percent. The textile tool rolls are classified with the tools they hold in accordance with General Rule of Interpretation 5(a) which states: Camera cases, musical instrument cases, gun cases, drawing instrument cases, necklace cases and similar containers, specially shaped or fitted to contain a specific article or set of articles, suitable for long-term use and entered with the articles for which they are intended, shall be classified with such articles when of a kind normally sold therewith. This rule does not, however, apply to containers which give the whole its essential character. You also inquired about the classification of the above items, except for the textile tool roll, shipped in bulk. Shipments may contain only bits, or a mixture of bits, screwdriver handles and adapters. The screwdriver handles and adapters imported in bulk would be classified under 8466.10.8075, HTS, which provides for tool holders for any type of tool for working in the hand. The rate of duty will be 3.9 percent. The screwdriver bits imported in bulk will be classified under HTS subheading 8207.90.6000 as other interchangeable tools: other: other: not suitable for cutting metal: for handtools. The rate of duty will be 4.3 percent. 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 Robert Losche at 212-637-7038. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division