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NY E89232




November 4, 1999

CLA-2-96:RR:NC:1: 115 E89232

CATEGORY: CLASSIFICATION

TARIFF NO.: 9608.10.0000,7326.90.8585,7419.99.5050

Mr. Gordon C. Anderson
C.H. Robinson International, Inc.
5995 Opus Parkway Suite 201
Minnetonka, MN 55343-9058

RE: The tariff classification of a Stationery Organizer, and Keyholders from Taiwan and China..

Dear Mr. Anderson:

In your letter dated October 29, 1999 you requested a tariff classification ruling of behalf of your client Barlow Promotional Products, Inc.

The first sample is a “Multi Worker”. This item has 11 functions and in appearance looks like a hand stapler. The items built into the body of this “11 in 1 Stationery Organizer” include a scissors, carton opener, stapler, small storage case for staples and paperclips, pen, staple remover, tape measure, paper punch, and pencil sharpener.

The second item, Style # B134BD, is a “Twist-lock Whistle Keyholder”. The keyholder is made of Brass but will also be made of Steel. The keyholder has a whistle built into the fob. The round shaped holder utilizes a spring load design that allows the ring to be pulled up to put the key in place and the spring snaps the ring back into the fob to secure the key.

The third item, Style # B162C, is a combination key holder with a golf divot tool with ball marker. The key holder is a tear drop shaped circle and utilizes a spring loaded gate that opens to put the key in place and snaps shut to secure the key. The keyholder is made of Brass but will also be made of Steel. The keyholder will be imported with or without the golf accessory attachment.

The samples will be returned as per your request.

Classification of the “11 in 1 Stationery Organizer” will be based on General Rules of Interpretation 3© which states that “When goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration”. In this sample the Ball Point Pen appears last in the Tariff.

The applicable subheading for the “11 in 1 Stationery Organizer” will be 9608.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Ball point pens. The rate of duty will be 0.8 cents each + 5.4% ad valorem.

The applicable subheading for the Keyholders (of Brass) will be 7419.99.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of Copper: Other: Other: Other. The rate of duty will be Free.

The applicable subheading for the Keyholders (of Steel) will be 7326.90.8585, Harmonized Tariff Schedule of the United States (HTS), which provides for Other articles of iron or steel: Other: Other: Other. The rate of duty will be 2.9% ad valorem.

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 212-637-7017.

Sincerely,

Robert B. Swierupski
Director,

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