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NY G85576




January 19, 2001

CLA-2-42:RR:NC:341:G85576

CATEGORY: CLASSIFICATION

TARIFF NO: 4205.00.8000; 4202.31.6000; 6307.90.9989; 7326.20.0050; 4202.32.9550; 3506.10.5000

Ms. Lynn Cummings
E-Z Leash, S.A.
P.O. Box 02-5635
Miami, Florida 33102

RE: The tariff classification of a wallet, accessory strap, split rings, glue and and E-Z Leash set from Costa Rica.

Dear Ms. Cummings:

In your letter dated December 15th, 2000, you requested a classification ruling.

The samples submitted with your request consist of four items. Item #1 consists of a wallet, an adjustable accessory strap, split rings, and glue, which are sold as a kit. The glue and three metal split rings are packed together in a plastic package. A tab of nylon webbing is attached to two of the split rings and the remaining split ring is attached to a plastic dog leash type clasp. The wallet has its own function; it provides portability, organization, and storage to the items placed therein. The strap and metal split rings do not share a common purpose with the wallet. Therefore, the items are not considered a set and are to be classified separately. The wallet and strap are made of textile material of man-made fibers. A metal split ring and a plastic dog-leash type clasp (which is attached to a metal split ring) are affixed to a metal d-ring sewn into the interior of the wallet; these are considered to be an integral part of the wallet and are not separately classified. The strap is a generic strap that can be used to hold items such as a camera and has a plastic clip at each end. The glue is used to affix the tab on the split rings to an item such as a cell phone. The split ring with the glued-on item can then be attached to the clasps at both ends of the textile strap. The textile strap can also be used to hold the wallet.

Items #2 and 4, identified as E-Z Leash, consist of an accessory strap that is sold as a kit with an adhesive, split ring(s) with a fabric tab, and metal and plastic snaphook(s). The accessory strap is affixed to a cellphone, small electronic devices, cameras, etc., by means of the split ring/tab or snaphook, and is worn around the waist, neck, over the shoulder, across the chest, or attached to a briefcase, purse, backpack or belt loop. The E-Z Leash kit will be imported ready for retail sale. The Explanatory Notes, which constitute the official interpretation of the HTSUSA at the international level, state in Note X to Rule 3(b) that the term “goods put up in sets for retail sale” means goods which:

(a) consist of at least two different articles which are ,prima facie, classifiable in different headings; (b) consist of products or articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking.

The individual items will be imported ready for retail sale and are separately classifiable under different headings in the HTS. The items meet the particular need of securing relatively small items and are considered a set. The strap imparts the essential character to the E-Z Leash set.

Item #3 is a coin purse made of leather. Both the interior and front pocket are secured by a zippered closure. A metal split ring with a metal dog leash type clasp is affixed to the top and side exterior. The split rings and clasps are considered an integral part of the purse and are classified with the purse.

The applicable subheading for the E-Z Leash set (items #2 and #4) will be 4205.00.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other articles of leather or of composition leather: Other: Other.” The rate of duty will be Free.

The applicable subheading for the coin purse of leather (item #3) will be 4202.31.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for articles of a kind normally carried in the pocket or handbag, other. The duty rate will be 8% ad valorem.

The applicable subheading for the wallet of item #1 will be 4202.32.9550, Harmonized Tariff Schedule of the United States (HTS), which provides for articles of a kind normally carried in the pocket or handbagof man-made fibers. The duty rate will be 18.3% ad valorem.

The applicable subheading for the accessory strap of item #1 will be 6307.90.9989, Harmonized Tariff Schedule of the United States (HTS), which provides for other made up articles, including dress patternsother. The duty rate will be 7% ad valorem.

The applicable subheading for the split rings of item #1 will be 7326.20.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for articles of iron or steel wire, other. The duty rate will be 3.9% ad valorem.

The applicable subheading for the glue of item #1 will be 3506.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for products suitable for use as glues or adhesives, put up for retail sale as glues or adhesives, not exceeding a net weight of 1 kg, other. The duty rate will be 2.1% 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 Kevin Gorman at 212-637-7091.

Sincerely,

Robert B. Swierupski
Director,

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