The tariff classification of a padlock and mounting assembly from China

N165695 May 26, 2011 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8301.10.8000 Ms. Silke Rees Customs Compliance Supervisor Master Lock Company P.O. Box 927 137 W. Forest Hill Avenue Oak Creek, WI 53154 RE: The tariff classification of a padlock and mounting assembly from China Dear Ms. Rees: In your letter dated May 9, 2011, you requested a tariff classification ruling. The submitted sample will be retained by this office. The merchandise under consideration, identified as model number 8252DAT Ladder Lock Locking Tie Down Point (Ladderlock), is a product designed to secure an extension ladder to the rack of a pickup truck or trailer. It will be packed in retail clamshell packaging upon importation. The Ladderlock comprises a steel receiver barbell lock and a mounting assembly that includes a steel hasp attached to a steel clamp collar. The barbell lock is a padlock consisting of a key operated cylinder locking head, a 5 inch long detachable lock pin that bolts into the locking head, and two keys. It measures 5.15 cm in width and has a fitted protective cover surrounding the locking head. The hasp includes plastic bracket covers and the clamp collar includes plastic adapters that enable the Ladderlock to mount to poles of various sizes. When in use, the lock pin is inserted through the loop of a cable or the ring of a tie-down strap (not included); it is then threaded through two holes in the hasp and locked in place with the locking head. Explanatory Note (EN) 3(b)(IX) indicates that “For the purpose of this Rule, composite goods made up of different components shall be taken to mean not only those in which the components are attached to each other to form a practically inseparable whole but also those with separable components, provided these components are adapted one to the other and are mutually complementary and that together they form a whole which would not normally be offered for sale in separate parts.” The Ladderlock is composed of a padlock and a mounting assembly that function effectively only when used together. We find that it meets the definition of a composite good and that its essential character is provided by the barbell lock. The applicable subheading for the 8252DAT Ladderlock will be 8301.10.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for padlocks and locks (key, combination or electrically operated), of base metal…padlocks, of cylinder or pin tumbler construction, over 3.8 cm but not over 6.4 cm in width. The rate of duty will be 4.8 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