The tariff classification of a tinplate iron bank from China

N310500 April 3, 2020 CLA-2-73:OT:RR:NC:N4:422 CATEGORY: Classification TARIFF NO.: 7323.99.5060 Jeannine Greener, LCB Air Tiger Express (USA), Inc. 18343 8th Avenue South Seattle, WA 98148 RE: The tariff classification of a tinplate iron bank from China Dear Ms. Greener: In your letter dated February 14, 2020, on behalf of your client, Magic & Miracles, you requested a tariff classification ruling. A sample of the item and additional information was received from your office. The sample will be returned to you as requested. The merchandise under consideration is identified as the Moonjar Moneybox, item #0972428216. The item contains three separate banks, three ABS (Acrylonitrile Butadiene Styrene) plastic lids, a yellow silicon rubber band, a paper marketing band, a guide booklet and a banking passbook. You have indicated in your letter that all three bank compartments are comprised of 99.85% iron and .15% tin. You have stated that all of the items are packaged together for retail sale upon importation. The bank compartments are diamond shaped and are made of tinplated iron. They are all identical in size and measure approximately 4.5 inches high by 4.5 inches wide. Each bank contains a removable lid with a money slot made of ABS plastic. The first bank is blue in color and features the word “Save” written onto its surface. The second bank is green in color and features the word “Spend” written onto its surface. The third bank is red in color and features the word “Share” written onto its surface. The three bank compartments are all held together with a yellow silicon rubber band that stretches around the banks. A paper marketing band that features product information fits around the banks. The guide booklet and banking passbook teaches children how to allocate and manage their money. In use, the child can remove the yellow silicon rubber band to separate the banks, enabling them to deposit or withdraw money in between the banks. The banking passbook enables the child to record how much money is in each bank compartment. You suggest classification of the Moonjar Moneybox as a toy in subheading 9503.00.0073, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Unlike the other types of “toy coin banks” classified in the toy provision, the instant product serves as functional containers and does not provide any amusement or role-play value and therefore does not meet the terms of heading 9503. The Moonjar Moneybox is a composite good comprised of different materials that are classifiable in different headings. Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 3(b) of the HTSUS provides, in relevant part, that composite goods which cannot be classified by reference to GRI 3(a) shall be classified as if they consisted of the material or component which gives them their essential character. The tinplate iron accounts for the vast majority of the weight and value for all three bank compartments. Therefore, the essential character of the Moonjar Moneybox is the tinplate iron banks. In accordance with GRI 3(b), the Moonjar Moneybox will be classified in heading 7323, which provides for Table, kitchen or other household articles and parts thereof, of iron or steel. The applicable subheading for the Moonjar Moneybox, item #0972428216 will be 7323.99.5060, HTSUS, which provides for Table, kitchen or other household articles and parts thereof, of iron or steel…Other: Other: Not coated or plated with precious metal: Of tinplate…Other. The rate of duty will be free. 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 the 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