The tariff classification of ClipKeys from China

N260296 January 13, 2015 CLA-2-83:OT:RR:NC:N4:414 Category: Classification Tariff NO.: 8301.70.0000 Ms. Ruth Umana Sales Coordinator Giant HQ LLC 4727 Wilshire Blvd. Suite 601-101 Los Angeles, CA 90010 RE: The tariff classification of ClipKeys from China Dear Ms. Umana: In your letter dated November 11, 2014, received by this office on December 17, 2014, you requested a tariff classification ruling. Samples were provided to this office and are being returned to you. The merchandise is called ClipKeys and identified as part #86926. ClipKeys are blanks for keys. The key blade and the rubber covered handle of the ClipKey are made in Mexico. We note that the handle is also frequently referred as the bow of a key. The key blade and rubber handle are shipped from Mexico to China. In China, the latch lock and the spring inside the latch lock are added to the key blade and rubber handle. The finished product is the key blade with a built-in carabiner. The carabiner’s rubber portion will feature various colors such as blue, green, purple, etc., for easy identification of the key. ClipKeys can be clipped onto a key ring, a purse, a backpack or belt loop. ClipKeys will be imported from China in a white cardboard box, packaged six ClipKeys to the box. The distributors of the product will resell the boxes to retail hardware stores. The retail hardware stores will remove the white box packaging and sell the individual carded key blanks to consumers. The applicable subheading ClipKeys will be 8301.70.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames for clasps incorporating locks, of base metal; keys and parts of any of the foregoing articles, of base metal; Keys presented separately. The rate of duty will be 4.5 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/. We note that the country of origin marking is Made in Mexico, Assembled in China on the individual cards and on the white cardboard boxes. The country of origin marking should state the country of origin of the components of the ClipKey and the country of assembly: Key Blade and Handle-Made in Mexico, Latch Lock and Spring-Made in China, Assembled in China. 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 Barbara Kiefer at barbara.j.kiefer@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division