The tariff classification of laptop locks from China

N075635 September 21, 2009 CLA-2-83:OT:RR:E:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8301.10.4000; 8301.10.5000; 8301.10.6000 Mr. Darren Lenox ACCO Brands 300 Tower Parkway Lincolnshire, IL 60069 RE: The tariff classification of laptop locks from China Dear Mr. Lennox: In your letter dated September 11, 2009, you requested a tariff classification ruling. The merchandise under consideration is four models of notebook locks that function to secure a laptop computer. Each is made of base metal and has an attached steel cable that can be looped around a fixed object, such as a desk or file cabinet. Each lock attaches to a computer by inserting a protruding node located on the lock body into the computer’s lock slot. The MicroSaver® Keyed Notebook Lock is also referred to as the Microsaver (model number K64068). This keyed lock has a locking mechanism of cylinder and pin tumbler construction. You have indicated in your letter that the maximum dimension of the lock body is no greater than 3.3 cm. The MicroSaver® Combination Notebook Lock is also referred to as the Small-sized Combosaver (model number K64344). It is a combination lock that measures 4.8 cm in width and operates by means of a series of rotating, numbered dials. The ComboSaver® Combination Lock is also referred to as the Push-button Combosaver (product number K64561). This combination lock measures 6.7 cm in width. It operates by means of a series of rotating, numbered dials along with a push button mechanism for ease of use. The ComboSaver® Master Coded Combination Notebook Lock is also referred to as the Master Coded Combosaver (product number K67710). This combination lock measures 6 cm in width. It operates by means of a series of rotating, numbered dials and also incorporates a trigger mechanism. This lock provides both combination and master “key” access when used in conjunction with a device that serves as an electronic opener, called a ComboGenie® (not included). You have indicated that you believe the MicroSaver® Combination Notebook Lock, the ComboSaver® Combination Lock, and the ComboSaver® Master Coded Combination Notebook Lock each measure less than 3.8 cm in width and should, therefore, be classified in subheading 8301.10.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for padlocks, not of cylinder or pin tumbler construction, not over 3.8 cm in width. This office disagrees with your assertion. The classification of a padlock depends upon its construction and width. The width is the dimension perpendicular to the length, measured at its greatest point. Upon review, we have determined that each of these three combination padlocks exceeds 3.8 cm in width. The applicable subheading for the MicroSaver® Keyed Notebook Lock (Microsaver) will be 8301.10.6000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…padlocks, of cylinder or pin tumbler construction, not over 3.8 cm in width. The rate of duty will be 6.1 percent ad valorem. The applicable subheading for the MicroSaver® Combination Notebook Lock (Small-sized Combosaver) and the ComboSaver® Master Coded Combination Notebook Lock (Master Coded Combosaver) will be 8301.10.4000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…padlocks, not of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The rate of duty will be 3.8 percent ad valorem. The applicable subheading for the ComboSaver® Combination Notebook Lock (Push-button Combosaver) will be 8301.10.5000, HTSUS, which provides for padlocks and locks (key, combination or electrically operated), of base metal…padlocks, not of cylinder or pin tumbler construction, over 6.4 cm in width. The rate of duty will be 3.6 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