The tariff classification of a drywall finishing and repair kit from China.

N004282 December 18, 2006 CLA-2-82:RR:NC:N1:118 CATEGORY: Classification TARIFF NO.: 8205.59.5510, 3214.90.5000 Ms. Winniefred Tucker L G Sourcing, Inc. PO Box 1000 Mailcode 4EIM Mooresville, North Carolina 28115 RE: The tariff classification of a drywall finishing and repair kit from China. Dear Ms. Tucker: In your letter dated November 28, 2006, you requested a tariff classification ruling for an eight-piece drywall finishing and repair kit. The sample is being returned as you requested. You state that the kit (item 245887) is used to repair cracks and crevices in sheetrock. The submitted sample consists of a plastic container with a bag that holds 1.5 lbs of drywall joint compound (drywall mud), a small sanding sponge made of alumina, a 10’’ plastic mud pan, a plastic corner tool, a 2’’ plastic putty knife, a 4’’ plastic putty knife, a 6’’ plastic putty knife and an 8’’ steel taping knife with a metal working edge. You describe the kit as “goods put up for retail sale.” You further state that the drywall compound may be imported as a part of the set or by itself. The compound is described as premixed and will be imported in the form of a ready to use paste. It is a nonrefractory compound made up of the following ingredients: 35% limestone, 35% water, 5% talc (non asbestos), 5% kaolin and 30% vinyl acetate polymer resin material. The applicable subheading for the eight piece drywall finishing and repair kit will be 8205.59.5510, Harmonized Tariff Schedule of the United States (HTSUS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other: other: other: of iron or steel: other: edged handtools: other. The rate of duty will be 5.3% ad valorem. If imported separately, the applicable subheading for the drywall compound will be 3214.90.5000, HTSUS, which provides for nonrefractory surfacing preparations for facades, indoor walls, floors, ceilings or the like. The rate of duty will be 6.5% ad velorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Kathy Campanelli at 646-733-3021. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division