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NY 874335



May 19, 1992

CLA-2-73:S:N:N1:115 874335

CATEGORY: CLASSIFICATION

TARIFF NO.: 7326.20.0050

Mr. Terry L. Lewis
C V International, Inc.
#16 The Koger Center
Suite 100
Norfolk, VA 23502

RE: The tariff classification of Key Rings from China and/or Hong Kong.

Dear Mr. Lewis:

In your letter dated May 6, 1992, you requested a tariff classification ruling, on behalf of your client, Ilco Unican Corporation, Rocky Mount, NC 27801.

The subject items are key rings. They are described as follows:
a) Article #294-00-51 - Belt Key Ring - Leather It consists of a steel key ring, a steel clip attachment and a leather strap. The article is made in China.
b) Article #226-14-51 - Snap Apart Key Ring It consists of 2 steel key rings and a steel attachment. The article is made in Hong Kong.
c) Article #293-14-51 - Belt Key Ring - Metal It consists of a steel key ring and a steel clip. The article is made in China.

The classification of merchandise under the HTS is governed by the General Rules of Interpretation (GRI'S). GRI 1, HTS, states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes...". This Rule applies to articles #226-14-51 and #293-14-51.

Article #294-00-51 is considered composite goods, consisting of different materials or made up of different components. This item shall be classified as if it consisted of the material or component which gives it its essential character. In this instance, the steel key ring imparts the essential character.

The applicable subheading for all three articles will be 7326.20.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel wire, other. The duty rate will be 5.7% ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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