RE: The tariff classification of a key fob from Portugal

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365339 October 14, 2026 CLA-2-79:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7907.00.6000 Rocco Kruse Rocco Kruse GmbH Anzengruberstrasse 23 12043 Berlin Germany RE: The tariff classification of a key fob from Portugal Dear Mr. Kruse: In your letter dated September 23, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The merchandise under consideration is a key fob identified as the “Millville Leather Key Fob,” sold under the brand EVENaBAG. This item is comprised of a leather strap with two metal attachments on each end. The leather strap is made of vegetable-tanned leather and is available in two colors; brown or black. The strap is sown together in two layers leaving openings on both ends to secure the metal attachments. The attachments are made of zinc and plated with nickel. One metal attachment is a closed D-ring that can accommodate split rings that are used to hold keys and other accessories such as charms. The other attachment is a lobster clasp on a swivel attached to another closed D-ring which can be used to attach the key fob to other accessories such as handbags or back packs. When fully manufactured, the EVENaBAG brand and logo are embossed on the leather strap with small red tag sown on one side identifying the key fob as an EVENaBAG product. We note that this item is constructed of various materials, and with no other heading identified specifically for the key fob, the item will be classified as a composite good under General Rule of Interpretation (GRI) 3(b) which 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.” The Explanatory Notes (ENs) to GRI 3(b) (VIII) state 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 value, or by the role of a constituent material in relation to the use of the goods.” In this case, based on the information provided, the metal pieces consisting of zinc carry the highest value and weight for this item and imparts the essential character. Therefore, the Millville Leather Key Fob is appropriately classified in Chapter 79, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Zinc and articles thereof.” Heading 7907, HTSUS, is a residual or basket provision which covers a wide range of zinc articles that are not more specifically provided for elsewhere in the HTSUS. An article of zinc can be classified in heading 7907 if it is determined that the item is not more specifically provided for in any other heading of the tariff. The key fob is not specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7907, HTSUS. The applicable subheading for the Millville Leather Key Fob will be 7907.00.6000, HTSUS, which provides for “Other articles of zinc: Other.” The general rate of duty will be 3 percent ad valorem. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Matthew Gay at matthew.gay@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division