The tariff classification of a suction tool holder from China
Issued March 19, 2013 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 3926.90.9980
Headings: 3926
Product description
The pictures submitted with your request depict a product marketed as an industrial “Clip-UM!” tool holder designed to hold cylindrical items such as tools, utensils and rods onto a wall. The holder consists of adjustable plastic jaws on a flat base plate. The plastic base plate measures approximately 3 inches square, while the jaws project outward approximately 2 inches. Although the product is listed as a “reusable adhesive clip,”
CBP rationale
The applicable subheading for the industrial Clip-UM! tool holder will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other.
Full text
N238639 March 19, 2013 CLA-2-39:OT:RR:NC:N4:421 CATEGORY: Classification TARIFF NO.: 3926.90.9980 Ms. Connie Cho Cocoon Worldwide, LLC DBA UM! Brands USA 13931 Central Avenue, Suite C Chino, CA 91710 RE: The tariff classification of a suction tool holder from China Dear Ms. Cho: In your letter dated February 19, 2013, you requested a tariff classification ruling. The pictures submitted with your request depict a product marketed as an industrial “Clip-UM!” tool holder designed to hold cylindrical items such as tools, utensils and rods onto a wall. The holder consists of adjustable plastic jaws on a flat base plate. The plastic base plate measures approximately 3 inches square, while the jaws project outward approximately 2 inches. Although the product is listed as a “reusable adhesive clip,” you state that there is no applied adhesive on the back. Rather, the product adheres to non-porous flat surfaces by means of “nanosuction.” You describe this feature as operating by means of millions of nano-sized suction cups creating a vacuum between the surface of the cups and a smooth non-porous surface. The clip can be used anywhere to hold items with a cylindrical handle. These clips are not meant for permanent installation but can be washed and moved from one surface to another. Washing the surface of soil particles reactivates the strong suction force. The applicable subheading for the industrial Clip-UM! tool holder will be 3926.90.9980, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 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 Joan Mazzola at (646) 733-3023. Sincerely, Thomas J. Russo Director National Commodity Specialist Division
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