CBP Ruling N035603 — The tariff classification of towel holders from China

Tariff classification

Headings: 8302

GRI rules applied: GRI 3

Product description

The merchandise under consideration is described as a “Dual Towel Holder,” item number 66320. It is a towel holder made of stainless steel and thermoplastic rubber and measures approximately 4-3/4 inches long by 2-7/8 inches wide by 1-1/4 inches high. It mounts to a wall by use of either four screws or double sided tape (both included). The stainless steel portion provides the structure and sleek appearance of the item. The rubber portion functions to grip the towel. Your letter indicates that it provides a sleek alternative to traditional hooks for hanging towels and that it is great for use in kitchens, bathrooms, laundry rooms and garages. Neither the base metal nor the rubber component imparts the product’s essential character. When the component that gives the product its essential character cannot be determined, classification is ascertained by way of GRI 3 (c). Applying GRI 3 (c), the merchandise is classifiable under heading 8302, Harmonized Tariff Schedule of the United States (HTSUS), since it occurs last in numerical order of the two competing subheadings.

CBP rationale

The applicable subheading for the base metal hooks will be 8302.50.0000, HTSUS, which provides for base metal mountings, fittings and similar articles…hat-racks, hat pegs, brackets and similar fixtures, and parts thereof.

Full text

N035603 September 9, 2008 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8302.50.0000 Ms. Francine Ramsey Hampton Direct Inc. 350 Pioneer Drive P.O. Box 1199 Williston, VT 05495 RE: The tariff classification of towel holders from China Dear Ms. Ramsey: In your letter dated August 8, 2008, you requested a tariff classification ruling. The sample you submitted will be retained by this office. The merchandise under consideration is described as a “Dual Towel Holder,” item number 66320. It is a towel holder made of stainless steel and thermoplastic rubber and measures approximately 4-3/4 inches long by 2-7/8 inches wide by 1-1/4 inches high. It mounts to a wall by use of either four screws or double sided tape (both included). The stainless steel portion provides the structure and sleek appearance of the item. The rubber portion functions to grip the towel. Your letter indicates that it provides a sleek alternative to traditional hooks for hanging towels and that it is great for use in kitchens, bathrooms, laundry rooms and garages. Neither the base metal nor the rubber component imparts the product’s essential character. When the component that gives the product its essential character cannot be determined, classification is ascertained by way of GRI 3 (c). Applying GRI 3 (c), the merchandise is classifiable under heading 8302, Harmonized Tariff Schedule of the United States (HTSUS), since it occurs last in numerical order of the two competing subheadings. The applicable subheading for the base metal hooks will be 8302.50.0000, HTSUS, which provides for base metal mountings, fittings and similar articles…hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The rate of duty will be free. 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 Barbara Kaiser at (646) 733-3024. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division

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