The tariff classification of an 18 Piece Screwdriver Bit Set from China

N218897 June 20, 2012 CLA-2-84:OT:RR:NC:1:104 CATEGORY: Classification TARIFF NO.: 8207.90.6000 Ms. Jamie Kuo Test Rite Int’l Co. Ltd. 6F., No. 23 Hsin Hu 3rd Road Hei Hu 114, Taipei Taiwan RE: The tariff classification of an 18 Piece Screwdriver Bit Set from China Dear Ms. Kuo: In your letter dated May 24, 2012, on behalf of your client Test Rite Products Corp., you requested a tariff classification ruling. Item number TS80046Z is an 18 piece Precision Screwdriver Bit Set. It is imported packaged for retail sale in a plastic case which is fitted for all of the components in the set. Nothing will be added to the set subsequent to importation. The contents of the set include: 1 – Precision Bit Driver with 2 two tone handle 16 – 1.1 inch Precision Screwdriver Bits: Dia.: 5/32” (4mm) Slotted: 1, 2, 2.5, 3mm Phillips: #00, #0, #1 Star: T5 x 3pc, T7, T8, T9, T10, T15, T20 1 – Bit Holder The above toolholder and bit set consists of at least two different articles that are, prima facie, classifiable in different headings. It consists of articles put up together to carry out a specific activity (i.e., tightening or loosening fasteners). Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the kit in question is within the term “goods put up in sets for retail sale.” General Rule of Interpretation (“GRI”) 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. As the only function of the imported kit is its ability to function as a screwdriver, it is the opinion of this office that the screwdriver bits impart the essential character to this toolholder and bit set. The applicable subheading for the Item number TS80046Z an 18 piece Precision Screwdriver Bit Set will be 8207.90.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for Interchangeable tools for handtools, whether or not power operated, or machine tools …: Other interchangeable tools, and parts thereof: Other: Other: Not suitable for cutting metal, and parts thereof: For handtools, and parts thereof. The rate of duty will be 4.3 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 Patricia O’Donnell at (646) 733-3011. Sincerely, Thomas J. Russo Director National Commodity Specialist Division