The tariff classification of an ignition key release tool from Germany.

N084035 November 17, 2009 CLA-2-82:OT:RR:NC:1:118 CATEGORY: Classification TARIFF NO.: 8205.59.5560 Mr. Robert Resetar Porsche Cars North America, Inc. 980 Hammond Drive Suite 1000 Atlanta, GA 30328 RE: The tariff classification of an ignition key release tool from Germany. Dear Mr. Resetar: In your letter dated November 9, 2009, you requested a tariff classification ruling. You describe item PCNA35b as an ignition key release tool. You state that this tool is made of stainless steel wire rod. It is 1.5 mm in diameter and 135 mm in length with a 5 mm right angle bend on one end. It is used to release the key from an automotive ignition switch if the key becomes stuck in the lock cylinder. The applicable subheading for the ignition key release tool 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: of iron or steel: other: other (including parts). The rate of duty will be 5.3% ad valorem. As an alternative classification to subheading 8205.59.5560, HTSUS, you proposed classifying the ignition key release tool under subheading 7326.20.0070, HTSUS, which provides for other articles of iron or steel. Classification under subheading 7326.20.0070, HTSUS, is precluded because the tool is covered by subheading 8205.59.5560, HTSUS. 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