The tariff classification of T-Post Clips from China

N070502 August 18, 2009 CLA-2-73:OT:RR:E:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.20.0070 Mr. Daniel Layne McDougall SunTouch Solar LLC 1625 West Williams Avenue Fallon, NV 89406 RE: The tariff classification of T-Post Clips from China Dear Mr. McDougall: In your letter dated July 31, 2009, you requested a tariff classification ruling. Photographs of the item were submitted for our review. The merchandise is identified as T-Post Clips. The clips are used in fencing to attach wire or barbed wire to studded T-Posts. Each clip is made of a 4 inch length of 12 1/2 gauge galvanized steel wire. You suggest classification of the T-Post Clip under subheading 7313.00.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for barbed wire of iron or steel; twisted hoop or single flat wire, barbed or not, and loosely twisted double wire, of a kind used for fencing, of iron or steel. However, the item under consideration is a piece of wire bent in an unusual configuration and used to secure the fencing to the post. It is not barbed wire and therefore does not meet the provisions of subheading 7313.00.0000, HTSUS. The applicable subheading for the T-Post Clips will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel: articles of iron or steel wire, other. The rate of duty will be 3.9 percent 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 Ann Taub at 646-733-3018. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division