The tariff classification of a "Telescoping Tree Pruner/Saw" from China.

N008137 March 21, 2007 CLA-2-82:RR:E:NC:N1:118 CATEGORY: Classification TARIFF NO.: 8201.90.6000 Ms. Debra Ann Godwin Customs Compliance Specialist Fiskars Brands, Inc. Garden & Outdoor Living 780 Carolina Street Sauk City, WI 53578 RE: The tariff classification of a “Telescoping Tree Pruner/Saw” from China. Dear Ms. Godwin: In your letter dated March 9, 2007, you requested a tariff classification ruling. The item you described is a telescoping tree pruner. The head of this item consists of a pruner designed to cut tree limbs up to 1” in diameter. A hook secures the tree limb while a steel blade is used to cut the limbs. Model number 9301 has an aluminum hook with a steel blade and model number 9390 has a plastic hook with a steel blade. The head assembly also has a 12” saw blade, which the consumer attaches to the pruner head. The saw is used to cut tree limbs over 1” thick. The assembly instructions, pruner, saw blade and bolts for assembly are all included in the imported retail package. Once the head assemblies are received in the U.S., the telescoping poles are attached to the imported packaged components. The applicable subheading for the tree pruner/saw head assemblies will be 8201.90.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for handtools of the following kinds and base metal parts thereof: spades, shovels, mattocks, picks, hoes, forks and rakes; axes, bill hooks and similar hewing tools; secateurs and pruners of any kind; scythes, sickles, hay knives, hedge shears, timber wedges and other tools of a kind used in agriculture, horticulture or forestry: other handtools of a kind used in agriculture, horticulture or forestry, and parts thereof: other. The duty rate will be free. Consideration was given to classifying your item within heading 8202, HTSUS, as you suggested, however, it was determined that the pruner portion of this composite good imparted the essential character. The pruner is a necessary component for the operation of the saw blade. If heading 8202 had been the appropriate heading, this item would not be classified within subheading 8202.10.0000, HTSUS, since the saw portion of this tool is a blade, not a handsaw or base metal part thereof. 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. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division