CBP Ruling N117976 — The tariff classification of a padlock from China

Tariff classification

Headings: 8301

Product description

The merchandise under consideration is described as a combination padlock, item number 175D. It is made of base metal, has a U-shaped shackle, and is operated by a combination locking mechanism with four numerical dials located at its base. The padlock also features a pin construction mechanism used to reset the combination, and a small key that is used as a reset tool. This key does not operate the locking mechanism; its purpose is to operate the reset mechanism to change and secure the lock’s combination. You have indicated in your letter that the key does not engage or release the shackle and that it cannot be inserted into the lock while the shackle is in the locked position. The padlock measures 7 cm in length and 5.1 cm in width overall.

CBP rationale

The applicable subheading for the combination padlock will be 8301.10.4000, Harmonized Tariff Schedule of the United States (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.

Full text

N117976 August 11, 2010 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8301.10.4000 Ms. Silke Rees Master Lock Company P.O. Box 627 137 W. Forest Hill Avenue Oak Creek, WI 53154 RE: The tariff classification of a padlock from China Dear Ms. Rees: In your letter dated August 2, 2010, you requested a tariff classification ruling. The sample you submitted will be retained by this office. The merchandise under consideration is described as a combination padlock, item number 175D. It is made of base metal, has a U-shaped shackle, and is operated by a combination locking mechanism with four numerical dials located at its base. The padlock also features a pin construction mechanism used to reset the combination, and a small key that is used as a reset tool. This key does not operate the locking mechanism; its purpose is to operate the reset mechanism to change and secure the lock’s combination. You have indicated in your letter that the key does not engage or release the shackle and that it cannot be inserted into the lock while the shackle is in the locked position. The padlock measures 7 cm in length and 5.1 cm in width overall. The applicable subheading for the combination padlock will be 8301.10.4000, Harmonized Tariff Schedule of the United States (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. 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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