The tariff classification of picture hanging kits and a plate hanger from China

N174979 July 27, 2011 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.90.8588; 7323.99.9080 Mr. M. Jason Cunningham Sonnenberg & Anderson 125 South Wacker Drive Suite 1825 Chicago, IL 60606 RE: The tariff classification of picture hanging kits and a plate hanger from China Dear Mr. Cunningham: In your letter dated July 13, 2011, on behalf of Liberty Hardware, Inc., you requested a tariff classification ruling on picture hanging kits and a plate hanger. Descriptions and photographs of the subject articles were submitted for our review. The subject merchandise is identified as picture hanging kits and a plate hanger. You stated in your letter that “Article 1 is marketed as a 12 pc Picture Hanger Kit and displayed within for sale within a hanging card and blister pack… Article 1 contains five types of items used together to hang pictures: (1) six D-ring hangers with (2) six corresponding screws for attachment of the D-Ring hangers to the side edges of a picture frame, (3) twelve feet of 20 gauge picture hanger wire, (4) five metal sawtooth picture hangers for attachment to the top edge of a picture, and (5) ten small nails corresponding with the fact that each of the five sawtooth hangers requires two nails. There are no extra or superfluous screws, nails, or other parts.” You indicated that “Article #2 is a set of ten picture hanger hooks measuring approximately 1.25” in length and .33” in width. Each picture hook has a hole at the top for use of one of the ten included nails to attach the picture hanger to the wall.” You stated that “Article three is a plate hanger…in its condition as imported…the plate hanger consists of two pieces of metal that are formed to create four hooks that wrap around the edge of a plate and hold it securely for vertical display upon a wall. These hooks are connected to each other by two metal springs to form one large plate hanger with four hooks. Also included within the set are one picture hanger hook and one nail for affixing it to a wall.” You indicated that “Article 4 consists of twenty-two picture hooks with the appropriate number of nails to use all twenty-two picture-hanging hooks. The included picture hanging hooks vary in the amount of weight they can support ranging from ten pounds to 75 pounds.” The metal that predominates by weight in each of the articles under consideration is steel. Each article in question is packed in a blister display pack ready for retail sale. The applicable subheading for the twelve piece picture hanger kit (article 1), the ten picture hanger hooks kit (article 2) and the twenty-two picture hanging hooks kit (article 4) will be 7326.90.8588, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem. The applicable subheading for the plate hanger (article 3) will be 7323.99.9080, HTSUS, which provides for table, kitchen or other household articles and parts thereof, of iron or steel…other, other, not coated or plated with precious metal, other, other, other. The rate of duty will be 3.4 percent ad valorem. Duty rates 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