The tariff classification of a gift set from China.

NY I85122 August 13, 2002 CLA-2-73:RR:NC:N1:113 I85122 CATEGORY: Classification TARIFF NO.: 7326.20.0070; 8214.10.0000; 9103.10.40 Ms. Lucia Buckman Associated Merchandising Corporation 500 Seventh Avenue New York, NY 10018 RE: The tariff classification of a gift set from China. Dear Ms. Buckman: In your letter dated August 5, 2002, you requested a ruling on tariff classification. The sample you provided is a gift set, item K91356-11. The set includes a desk clock, a letter opener and a key ring. The clock is 7 cm. wide, 2 cm. deep and 8.5 cm high. The face of the clock is 3 cm. in diameter. It is made of zinc alloy with an acrylic back. It is battery operated. The applicable subheading for the desk clock will be 9103.10.40, Harmonized Tariff Schedule of the United States (HTS), which provides for clocks with watch movements, excluding clocks of heading 9104; electrically operated; other; having no jewels or only one jewel in the movement. The general rate of duty will be 24 cents each plus 4.5 percent on the case plus 3.5 percent on the battery. The letter opener is made of a zinc alloy with an acrylic backing on the handle. It is 7.5 cm. long. The applicable subheading for the letter opener will be 8214.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for paper knives, letter openers, erasing knives, pencil sharpeners (nonmechanical) and blades. The general rate of duty will be 0.3 cents each plus 4.2 percent ad valorem. The key ring consists of a steel split ring, 3 cm. in diameter, with a metal and acrylic attachment, 5.5 cm. long. Although you state that the key ring is made of zinc, both the ring and the attachment attract a magnet, showing that there is substantial iron or steel. The classification of composite articles of two or more base metals is controlled by Section XV, Note 7, HTS, which states, in pertinent part: Except where the headings otherwise require, articles of base metal (including articles of mixed materials treated as articles of base metal under the General Rules of Interpretation) containing two or more base metals are to be treated as articles of the base metal predominating by weight over each of the other metals. For purposes of this ruling, we are assuming that the key ring is in predominating weight of steel. The applicable subheading for this product will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The general rate of duty will be 3.9 percent 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 James Smyth at 646-733-3018. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division