The tariff classification of a jewelry storage frame from China

N201616 February 17, 2012 CLA-2-44:OT:RR:NC:2:230 CATEGORY: Classification TARIFF NO.: 4414.00.0000 Ms. Joan Wong Williams Sonoma, Inc. 151 Union Street, 7th Floor San Francisco, CA 94111 RE: The tariff classification of a jewelry storage frame from China Dear Ms. Wong: In your letter dated January 18, 2012, you requested a tariff classification ruling. The ruling was requested on a “Jewelry Storage Frame” identified by two sku numbers, 7434145 and 7483365, which are designated for online purchases and in-store retail purchases, respectively. You submitted one sample of the “Jewelry Storage Frame” for our examination, which will be returned to you as requested. The “Jewelry Storage Frame” is designed to resemble a six pane window and measures approximately 30 inches wide x 24 inches high x 1 inch deep. The outer frame is constructed of 1 3/4-inch-wide boards, and the panes are separated by 1-inch-wide boards. The six panes are backed with alternating panels of iron wire netting and 100 percent linen fabric with 5mm EVA backing over wood. The upper edges of the top three panes, as well as that of the bottom center pane, are each mounted with seven iron wire hooks. The perimeter of the frame is enhanced with eleven wooden knobs, four on each side and three on the bottom of the frame. The hooks, knobs, and wire mesh are used to hang necklaces, earrings, and other pieces of jewelry. The back of the frame has two saw tooth hangers to facilitate hanging the frame on a wall. General Rule of Interpretation (“GRI”) 3(b) of the Harmonized Tariff Schedule of the United States (“HTSUS”) states as follows: (b) Mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character, insofar as this criterion is applicable. The “Jewelry Storage Frame” is made up of materials, including wood, textile, and iron wire, that are prima facie classifiable in different headings. As such, the item is a composite good within the meaning of GRI 3(b). GRI 3(b) states that composite goods are to be classified according to the material or component that gives them their essential character. While the hooks and mesh are functional, and together with the textile, contribute to the visual impact of the item, it is the wood frame that predominates in visual impact and weight. It is the wood that gives the item its windowpane structure. The wood therefore imparts the essential character of the “Jewelry Storage Frame”. The applicable subheading for the jewelry storage frame will be 4414.00.0000, HTSUS, which provides for Wood frames for paintings, photograph, mirrors or similar objects. The rate of duty will be 3.9 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 Laurel Duvall at (646) 733-3035. Sincerely, Thomas J. Russo Director National Commodity Specialist Division