The tariff classification of a faux fur key fob from China

N276387 June 28, 2016 CLA-2-79:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7907.00.6000 Mr. Yonjune Kim Customs Compliance Specialist PVH 200 Madison Avenue New York, NY 10016 RE: The tariff classification of a faux fur key fob from China Dear Mr. Kim: In your letter dated May 12, 2016, you requested a tariff classification ruling. A sample of the article under consideration was submitted for our review and will be returned to you as requested. The subject article is identified in your letter as a faux fur key fob, style number 7650. The article is composed of a zinc snap hook, two zinc split d-rings, a zinc CK initial dangle, a polyurethane strap and an acrylic faux fur pom pom. The faux fur key fob is a composite article that consists of a zinc snap hook, two zinc split d-rings, a zinc CK initial dangle, a polyurethane strap and an acrylic faux fur pom pom. The zinc, polyurethane and acrylic components 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 zinc, polyurethane and acrylic components of the faux fur key fob in combination, GRI 1 cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite good 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 faux fur key fob 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 zinc, polyurethane or acrylic component imparts the essential character to the faux fur key fob 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 faux fur key fob under consideration is to hold various items by means of attaching or connecting the zinc snap hook to a backpack, belt, pocketbook, etc. Therefore, it is the opinion of this office that the zinc components impart the essential character to the faux fur key fob. In accordance with GRI 3(b), the faux fur key fob under consideration will be classified as an other article of zinc. The applicable subheading for the faux fur key fob, style number 7650, will be 7907.00.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of zinc, other. The rate of duty will be 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 https://hts.usitc.gov/current. 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, Steven A. Mack Director National Commodity Specialist Division