The tariff classification of key rings from China

N237273 January 23, 2013 CLA-2-76:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7616.99.5090 Ms. Jill Stavos Norwood Bic Graphic North America 5151 Moundview Drive Red Wing, MN 55066 RE: The tariff classification of key rings from China Dear Ms. Stavos: In your letter dated January 7, 2013, on behalf of Norwood/Bic Advertising Promotional Products, you requested a tariff classification ruling. Samples of the subject key rings were submitted for our review. The merchandise under consideration is identified in your letter as cable key rings (Norwood items 20618 and 21051). Item 20618 consists of a round aluminum key fob and a stainless steel cable loop that is encased in plastic. The key fob measures approximately 1 inch in diameter and the cable loop measures approximately 5 inches in length. One end of the cable loop is permanently attached to the key fob on the left side of the top. The other end of the cable loop is inserted into the right side of the top of the key fob with a fitting that secures it. The cable can be released from the fob by pushing a small button located on the right side of the key fob. After the user places keys on the cable loop, the cable is inserted back into the fob to securely hold the keys. Item 21051 consists of a rectangular aluminum key fob and a stainless steel cable loop. The key fob measures approximately 1 1/2 inches in length by 1 inch in width by 3/16 inch in depth and has a hole that runs through the right and left side of the fob. The cable loop measures approximately 5 1/4 inches in length and has a threaded fitting on each end. Each end of the cable loop fits through the hole in the fob to form a loop. The cable ends are secured with steel balls that have threaded holes. One steel ball is removed to release one end of the cable. After keys are placed on the cable, the cable is inserted back into the fob and secured with a steel ball. You suggested classification in chapter 73, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles of iron or steel because you considered the stainless steel cable the essential character. However, when classifying an article made of two different base metals, there is no determination of essential character. Principal weight is the sole determining factor. Section XV, Note 7, indicates that the classification of composite articles of base metal containing two or more base metals are to be treated as articles of the base metal predominating by weight over each of the other metals. The metal in the subject key rings that predominates by weight is aluminum. Therefore, the articles in question are not classifiable in chapter 73, HTSUS, as articles of steel because the aluminum predominates by weight. The subject key rings are classified in chapter 76, HTSUS, which provides for articles of aluminum. The applicable subheading for the key rings will be 7616.99.5090, HTSUS, which provides for other articles of aluminum, other, other, other, other, other, other. The rate of duty will be 2.5 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, Thomas J. Russo Director National Commodity Specialist Division