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NY C86588




May 6, 1998

CLA-2-82:RR:NC:1:115 C86588

CATEGORY: CLASSIFICATION

TARIFF NO.: 8211.93.0030

Mr. Louis S. Shoichet
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway
43rd Floor
New York, NY 10036-8901

RE: The tariff classification of a 14-in-1 Tool from China

Dear Mr. Shoichet:

In your letter dated April 8, 1998 on behalf of Avon Products, Inc. you requested a tariff classification ruling.

The 14-in-1 tool is a steel-metal multi-purpose tool measuring approximately 4 inches in length in the closed position. The following components make up the tool: pliers, wire cutter, knife, scissors, saw, file, serrated knife, can opener, bottle opener, Philips head, 3 flat blade drivers and a mini-pen light to illuminate the immediate tool surface. The multi-purpose tool is specially fitted into a textile case and imported as such.

The instant merchandise comprises a composite article with various components. The headings at issue refer to part only of the materials or substances contained in the composite good, and, according to GRI 3(a), are to be regarded as equally specific, thereby making resort to GRI 3(b) necessary as each of the components contribute equally to the use of the article, classification is determined by reference to GRI 3(c) which provides for classification under those which equally merit consideration.

The knife part of the total tool is last in the tariff, and its subheading would be the basis of classification. Accordingly, the multi-tool is classifiable in subheading 8211.93.0030, Harmonized Tariff Schedule of the United States (HTS) at 3 cents each plus 5.4 percent ad valorem. Please note the mini-pen light was not given any consideration under the GRI's. The specially shaped and fitted case is of a kind normally sold with the tool and is classified with its contents in accordance with GRI 5(a).

The sample is being returned to your office in compliance with your request.

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 Melvyn Birnbaum at 212-466-5487.

Sincerely,

Robert B. Swierupski
Director,

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