The tariff classification of a towel bar, a towel ring, a toilet paper holder, a hook and a grab bar from Japan

N038478 October 14, 2008 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 7418.20.1000; 8302.50.0000; 8302.41.9080 Ms. Frances Y. Wing Toto 7700 Spence Road Fairburn, GA 30213 RE: The tariff classification of a towel bar, a towel ring, a toilet paper holder, a hook and a grab bar from Japan Dear Wing: In your letter dated September 11, 2008, you requested a tariff classification ruling. The merchandise under consideration is wall-mounted bathroom accessories made of brass with a polished chrome finish, a brushed nickel finish or a polished nickel finish. All products come with mounting hardware for both drywall and tile installation. Product number YB960 is the Soiree Towel Bar, which measures 24 inches long. Product number YR960 is the Soiree Towel Ring. Product number YP960 is the Soiree Paper Holder, which holds toilet paper. Product number YH960 is the Soiree Robe Hook. Product number YG96024 is the Soiree Grab Bar. You’ve indicated that you believe these products are classified as sanitary ware in subheading 7418.20.5000, Harmonized Tariff Schedule of the United States (HTSUS). We agree that the toilet paper holder is classified in this subheading since it is specifically referred to in Explanatory Note 73.24, however, the remaining products are more specifically described by the terms of heading 8302, HTSUS. The applicable subheading for the towel bar, towel ring and robe hook 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. The applicable subheading for the toilet paper holder will be 7418.20.1000, HTSUS, which provides for table, kitchen or other household articles and parts thereof, of copper…sanitary ware and parts thereof, of copper-zinc base alloys (brass). The rate of duty will be 3 percent ad valorem. The applicable subheading for the grab bar will be 8302.41.9080, HTSUS, which provides for base metal mountings, fittings and similar articles…other mountings, fittings and similar articles, and parts thereof, suitable for buildings, other, other, other. The rate of duty will be 3.5 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 Barbara Kaiser at (646) 733-3024. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division