The tariff classification of nametags from China

N010728 May 10, 2007 CLA-2-73:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7323.99.9060 Ms. Melissa Hermann Williams-Sonoma, Inc. 151 Union Street San Francisco, CA 94111 RE: The tariff classification of nametags from China Dear Ms. Hermann: In your letter dated April 25, 2007, you requested a tariff classification ruling. The merchandise is identified in your letter as nametags, SKU number 9507856, which serve as both napkin rings and placeholders. You indicate that the nametags will be imported and retailed through Pottery Barn retail stores in the United States. The submitted sample consists of four iron tags with split wire rings, four 19 inch pieces of sisal twine, and an erasable gold ink marker. The rectangular tags are painted with a bronze color. The tags with the twine attached are packaged with the marker in a cardboard box for retail sale. The tags are designed to be used as placeholders and the twine is intended to be tied around napkins. After wrapping the twine, the consumer can use the marker to write a name on the tag. You propose classification of the nametags, SKU number 9507856, in heading 5609, Harmonized Tariff Schedule of the United States (HTSUS), which provides for articles of yarn, strip or the like of heading 5404 or 5405, twine, cordage, rope or cables, not elsewhere specified or included. However, the twine is not considered the essential character of the nametags. It is the opinion of this office that the essential character is imparted by the iron tags. Your sample is being returned as requested. The applicable subheading for the nametags, SKU number 9507856, will be 7323.99.9060, HTSUS, which provides for table, kitchen or other household articles and parts thereof, of iron or steel, other, other, not coated or plated with precious metal, other, other, other. The rate of duty will be 3.4 percent ad valorem. 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 Ann Taub at 646-733-3018. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division