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NY 809982




May 12, 1995

CLA-2-82:S:N:N3:115 809982

CATEGORY: CLASSIFICATION

TARIFF NO.: 8205.40.0000

Tom Wat Inc. c/o Wheels Up Customs Brokerage and Forwarding 167-43 Porter Road
Jamaica, NY 11434
Attn: Mr. Salvatore J Stile II

RE: The tariff classification of a 4 in 1 Tool Key Chain from Hong Kong.

Dear Mr. Stile:

In your letter dated May 2, 1995, you requested a tariff classification ruling, on behalf of your client, Tom Wat Inc., Connecticut.
The subject article is called a 4 in 1 tool key chain. It is made of metal, covered with brass plating. It encompasses a key ring and chain that has a miniature hammer attached to the end of the chain. This hammer has a hollow inside and serves as a container for three miniature screwdrivers. When the bottom end of the hammer is unscrewed, access is gained to the screwdrivers. All parts except for the key ring and chain, can be separated from each other.

The subject article is a composite article that prima facie appears to be classifiable under more than one heading, each equally specific. Classification will accordingly be determined on the basis of that portion of the article which imparts the essential character. We have concluded that there is no essential character for this composite article.
Therefore, it shall be classified under the heading which occurs last in numerical order among those which equally merit consideration. In this instance, the hammer in HTS 8205.20.3000 and the screwdriver in HTS 8205.40.0000 merit equal consideration.

The applicable subheading for the 4 in 1 tool key chain will be 8205.40.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for screwdrivers, and parts thereof. The duty rate will be 6.2% 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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