The tariff classification of a plastic key-like component with an aluminum extension rod

N269468 November 4, 2015 CLA-2-39:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 3926.90.9995 Mr. Jeffrey Stapleton M.E. Dey & Co., Inc. 700 W. Virginia St Suite 300 Milwaukee, WI 53204-1539 RE: The tariff classification of a plastic key-like component with an aluminum extension rod Dear Mr. Stapleton: In your letter dated September 17, 2015, which was received in this office on October 7, 2015, on behalf of InPro Corporation, you requested a tariff classification ruling. The submitted sample is identified as an Operating Wand, part CE8621. The item is comprised of a plastic key-like component that measures approximately 2” in length and an attached aluminum rod that measures approximately 43” in length. The plastic key-like component is designed to fit into the locking mechanism on a Safety Loading Unit (not included), that is connected to a ceiling-mounted track on which privacy curtains are mounted in a hospital room. The key-like component of the wand locks and unlocks the Safety Loading Unit to enable hospital employees to lower a section of track to remove curtains for cleaning. The aluminum rod is designed to enable the user to reach the ceiling mounted Safety Loading unit with the plastic key-like component. This item is considered to be a composite good within the meaning of General Rule of Interpretation (GRI) 3. The plastic key-like component performs the primary role of locking and unlocking the Safety Loading Unit. The aluminum rod performs the subordinate role of enabling the user to reach the ceiling mounted Safety Loading Unit with the plastic key-like component. Therefore, it is the opinion of this office that the plastic key-like component provides this item with the essential character within the meaning of GRI 3(b). The applicable subheading for part CE8621 will be 3926.90.9995, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics…: other: other…other. 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 Gary Kalus at gary.kalus@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division