The tariff classification of cable cleats from the UK

NY L82605 March 8, 2005 CLA-2-73:RR:NC:N1:113 L82605 CATEGORY: Classification TARIFF NO.: 7326.90.8587; 7616.99.5090; 3926.90.9880 Ms. Jill L. Sherman J. W. Allen & Co., Inc 200 Crofton Road, Box 34 Bldg. 7D, Suite 800 Kenner, LA 70062 RE: The tariff classification of cable cleats from the UK Dear Ms. Sherman: In your letter dated February 7, 2005, on behalf of kVA Strategies, LLC, you requested a tariff classification ruling. The merchandise is a number of cable cleats. Cable cleats are used to hold and secure single high voltage cables or bundles of cables. The Aluminum Trefoil Cleats are made of aluminum. The Two Hole Cable Clamps are made of plastic. The Vulcan and the Emperor Cable Cleats are made of stainless steel. The Varicleat has a base of aluminum and a strap of steel. The Atlas Cable Cleat is made of galvanized steel. In your letter, you suggest classification under heading 7307, HTS, as pipe fittings, or heading 8479, HTS as mechanical appliances. The cleats, however, are not used to join pipe, nor do they have the functions of tube or pipe. Neither are they mechanical appliances. They are most similar to the exemplars mentioned in the Explanatory Notes to Section XV, Chapter 73. The applicable subheading for the steel cleats will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other. The rate of duty will be 2.9 percent ad valorem. The applicable subheading for the aluminum cleats, including the Varicleat, will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of aluminum, other. The rate of duty will be 2.5 percent ad valorem. The applicable subheading for the plastic cleat will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTS), which provides for "Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other, Other." The rate of duty will be 5.3% ad valorem. 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 James Smyth at 646-733-3018. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division