The tariff classification of a key ring from China

N267088 August 10, 2015 CLA-2-79:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7907.00.6000 Ms. Lena Rainbow Customs Compliance Specialist PVH 200 Madison Avenue New York, NY 10016 RE: The tariff classification of a key ring from China Dear Ms. Rainbow: In your letter dated July 27, 2015, you requested a tariff classification ruling on a key ring. You have submitted a sample which will be returned as you requested. The key ring under consideration is composed of an iron split wire ring that is attached to a connector link at the top of a square zinc trinket. The split ring is also attached to a polyurethane loop on one end of a polyurethane strap that has an iron insert set into the front of the strap. The strap measures approximately 2 5/8” in length by 3/8” in width. The key ring in question is a composite article that consists of iron, zinc and polyurethane components that are classified in different headings. Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) 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 iron, zinc and polyurethane components of the subject key ring 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. As the key ring is a composite good, we must apply rule GRI 3(b), which provides that composite goods are to be classified according to the component that gives the goods their essential character. EN VIII to GRI 3(b) explains that “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or the use of the goods.” We must determine whether the polyurethane or metal components impart the essential character to the key ring in question. It is the role of the constituent materials or components in relation to the use of the good that imparts the essential character. In this case, the function of the key ring under consideration is to hold keys and the metal components perform the function of holding the keys. Therefore, it is the opinion of this office that the metal components impart the essential character to the key ring. In accordance with GRI 3(b), the key ring under consideration will be classified as an other article of metal. You stated in your letter that the key ring in question is composed of more than one base metal. The key ring is composed of iron and zinc. Section XV, Note 7 of the HTSUS, states 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 that predominates by weight over each of the other metals. Based on the information provided to our office, the metal in the subject key ring that predominates by weight is zinc. Therefore, the article in question is classifiable in heading 7907, HTSUS, which provides for other articles of zinc. The applicable subheading for the key ring, will be 7907.00.6000, HTSUS, which provides for other articles of zinc, other. The rate of duty will be 3 percent ad valorem. You indicated in your letter that the key ring will be imported packaged together with a wallet in a cardboard box, style number 5677. We have already ruled on the classification for the wallet in the box for style number 5677 in New York Ruling N265514 dated July 6, 2015. 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 Ann.Taub@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division