The tariff classification of a key ring from China

N284144 March 17, 2017 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.20.0071 Ms. Kathy Trotta Conair Corporation 150 Milford Road East Windsor, NJ 08520 RE: The tariff classification of a key ring from China Dear Ms. Trotta: In your letter dated February 28, 2017, you requested a tariff classification ruling. A sample of the subject article was submitted for our review and will be returned to you as requested. The item under consideration is a key ring that was identified in your letter as a key chain. The key ring consists of an iron split wire ring, a short iron or steel chain attached to one pink acrylic heart, two hearts made of aluminum, a snap hook made of zinc alloys, and three decorative ribbons made of polyester. The key ring under consideration is a composite article that consists of an iron split wire ring, an iron or steel chain, an acrylic heart, two aluminum hearts, a zinc snap hook and polyester ribbons. The iron or steel, acrylic, aluminum, zinc and polyester 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 iron or steel, acrylic, aluminum, zinc and polyester components of the 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 iron or steel, acrylic, aluminum, zinc or polyester component imparts 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 iron component performs the function of holding the keys. Therefore, it is the opinion of this office that a metal component imparts 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 have indicated in your letter that the key ring is composed of more than one base metal. The key ring is composed of iron, steel, aluminum 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 and our examination of the submitted sample, the metal in the key ring that predominates by weight is iron. Therefore, the subject key ring is classifiable in heading 7326, HTSUS, which provides for other articles of iron or steel. The applicable subheading for the key ring that has been identified as a key chain will be 7326.20.0071, HTSUS, which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 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