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NY 817767





January 27, 1996

CLA-2-73:R:N4:119 817767

CATEGORY: CLASSIFICATION MARKING

TARIFF NO.: 3926.90.2500; 7318.15.2060; 7318.16.0080; 7326.90.8585

Mr. Jack D. Mlawski
Galvin & Mlawski
440 Park Avenue South - 9th Floor
New York, NY 10016-8067

RE: The tariff classification of parts of folding knives from Hong Kong and Taiwan

Dear Mr. Mlawski:

In your letter dated December 12, 1995 you requested a tariff classification and country of origin marking ruling on behalf of Zelco Industries, Mt. Vernon, NY.

The articles to be imported are parts for two models of folding knives to be assembled in the United States with blades of U.S. origin. Based on the samples furnished, the two models are slightly different in shape but are otherwise identical.

The two knives measure approximately 4 inches in overall length in the closed position and have a 2 1/2 inch blade. They have a release/lock mechanism in the handle that operates in the following manner: When the lever or bar of the mechanism is pressed, the blade protrudes slightly to allow the user to pull the blade out of the handle. When the blade is fully extended it locks in position.

Specifically, the imported items will consist of plastic handles and metal parts of the release/lock mechanism as follows.

Items K11001 and K11002 are plastic handles for the knives.

Item K11404 is a steel bolt that is threaded at the bottom.

Item K11406 is a locking ring or nut.

Item K11207/K11407 is a bar or lever with an anchor stem at one end.

Item K11405 is the center post for the mechanism. It is approximately 3/8 of an inch high with a maximum diameter of 1/4 of an inch. It has the general configuration of a miniature candle holder with a thick base.

The applicable subheading for the two plastic handles will be 3926.90.2500, Harmonized Tariff Schedule of the United States (HTS), which provides for handles and knobs, not elsewhere specified or included, of plastics. The duty rate will be 6.5 percent.

The applicable subheading for the steel bolt will be 7318.15.2060, HTS, which provides for screws, bolts, nuts... of iron or steel...other... bolts... The rate of duty will be 0.4 percent.

The applicable subheading for the locking ring or nut will be 7318.16.0080, HTS, which provides for screws, bolts, nuts... of iron or steel... other... nuts. The rate of duty will be 0.1 percent.

The applicable subheading for the bar or lever (K11207/K11407) and the center post (K11405) will be 7326.90.8585, HTS, which provides for other articles of iron or steel... other. The rate of duty will be 4.6 percent.

Please note the provisions for parts of knives were deleted from the tariff pursuant to Presidential Proclamation 6857 of December 11, 1995, published in the Federal Register of Friday December 15, 1995, Vol. 60, No. 241.

In regard to the country of origin marking requirement, since these components will not be sold in their imported condition but will be used in the manufacture of finished knives, Zelco Industries is considered to be the ultimate purchaser of these components and only the containers need be marked with the country of origin.

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.

If you have any questions pertaining to this matter, please contact National Import Specialist Jacques Preston of this office at (212) 466-5488.

Sincerely,

Roger J. Silvestri
Director

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