The tariff classification of a key ring with a letter opener and a flashlight from China

N261740 March 10, 2015 CLA-2-82:OT:RR:NC:N4:110 CATEGORY: Classification TARIFF NO.: 8214.10.0000 Mr. Ray Reel National Pen Tennessee 342 Shelbyville Mills Road Shelbyville, TN 37160 RE: The tariff classification of a key ring with a letter opener and a flashlight from China Dear Mr. Reel: In your letter dated February 11, 2014, received by this office on February 13, 2015, you requested a tariff classification ruling. A sample was submitted with your request and will be returned to you. The merchandise under consideration is identified as a key ring incorporating a letter opener and a flashlight, SKU FLC. The item is a combination of a letter opener, a key ring and an LED flashlight. The letter opener is attached to a metal split key ring with an LED lamp affixed to the front. The LED lamp is battery powered and controlled by a press-button switch located in the body of the letter opener. The battery is not replaceable. The letter opener is oval-shaped and has an internal metal blade. The letter opener is made of plastic and measures approximately 2.75 inches by 2.5 inches at it widest point. The item is considered a composite good. General Rule of Interpretation (GRI) 3 (b) provides that mixtures, composite goods consisting of different materials or made up of different components, and goods put up in sets for retail sale shall be classified as if they consisted of the material or component which gives them their essential character. This office regards the letter opener as imparting the essential character, whether by virtue of weight or value, and will therefore classify the article as such. The applicable subheading for the key ring incorporating a letter opener and a flashlight, SKU FLC, will be 8214.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of cutlery (for example, hair clippers, butchers’ or kitchen cleavers, chopping or mincing knives, paper knives); manicure or pedicure sets and instruments (including nail files); base metal parts thereof: paper knives, letter openers, erasing knives, pencil sharpeners (nonmechanical) and blades and other parts thereof. The rate of duty will be 0.3¢ each plus 4.2% 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 Hope Abada at [email protected]. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division