The tariff classification of components of a Yard Hanger System from China

N106750 June 4, 2010 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7323.99.9060 Mr. David Sayler WoodLink Ltd 1500 WoodLink Drive P.O. Box 508 Mount Ayr, Iowa 50854 RE: The tariff classification of components of a Yard Hanger System from China Dear Mr. Sayler: In your letter dated May 14, 2010, you requested a tariff classification ruling on five components of a Yard Hanger System. The items under consideration are components of a line of garden products identified as Slot ‘N Pin™. The products are used for hanging bird feeders, bird houses and other garden accessories. Each component in the Slot ‘N Pin™ product line is imported and sold individually. Each component is designed to be used in combination with other components to form a complete article. An individual component is not capable of functioning on its own. All of the items at issue are part of a Yard Hanger System and are made of steel. Item number SP1 is described as a single pole connector. It measures approximately 7.5 inches by 1.5 inches by 1 inch. Item number SP2 is described as a double pole connector. It measures approximately 7.5 inches by 2.25 inches by 1 inch. Item number SP3 is described as a triple pole connector. It measures approximately 7.5 inches by 2.25 inches by 1.75 inches. Item number SP4 is described as a quad pole connector. It measures approximately 7.5 inches by 2.25 inches by 2.25 inches. You stated that the only difference between the four pole connectors is the number of slotted connectors/adaptors that can accommodate other components. Item number SP14 is described as a heavy duty 32 inch pole extension. It measures approximately 34 inches by 1 inch by 1 inch. Samples of item number SP3 (triple pole connector) and item number SP14 (heavy duty 32 inch pole extension) were submitted for our review. You indicated in your letter that based on New York Ruling N101936 dated April 23, 2010, you propose classification in subheading 8302.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articles…hat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The National Import Specialist that handles heading 8302, HTSUS, has noted that the Yard Hanger System stakes to the ground and the components do not mount to a wall, deck, etc. Therefore, classification for the subject components in heading 8302, HTSUS, is not appropriate. The applicable subheading for the components of a Yard Hanger System identified as item numbers SP1, SP2, SP3, SP4 and SP14 will be 7323.99.9060, HTSUS, which provides for table, kitchen or other household articles and parts thereof, of iron or steel…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