The tariff classification of zipper pulls from China

N188376 October 20, 2011 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3926.90.9980 Ms. Kathy Trotta Conair Corporation 150 Milford Road East Windsor, NJ 08520 RE: The tariff classification of zipper pulls from China Dear Ms. Trotta: In your letter dated October 7, 2011, you requested a tariff classification ruling. A sample of the zipper pull was submitted with your letter and will be returned as requested. The zipper pull, model number EM4ZP, is comprised of a plastic grip and a textile cord. The zipper pull can be installed by inserting the textile cord through the zipper hole and then passing the plastic grip through the cord and pulling snug. The textile cord is used to secure the zipper pull to the zipper. The plastic grip is used to pull the zipper up or down. Classification of merchandise under the Harmonized Tariff Schedule of the United States is in accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification shall be determined according to the terms of the headings and any relative section or chapter notes. Since no one heading in the tariff schedules covers the components of the zipper pull in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. In this case, the essential character of the zipper pull is imparted by the plastic grip. The applicable subheading for the zipper pull, model EM4ZP, will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 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 Joan Mazzola at (646) 733-3023. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division