The tariff classification of a multi-function keychain from China.

N263518 April 27, 2015 CLA-2-82:OT:RR:NC:N1:118 CATEGORY: Classification TARIFF NO.: 8205.51.3030 Mr. Ray Reel National Pen Tennessee 342 Shelbyville Mills Road Shelbyville, TN 37160 RE: The tariff classification of a multi-function keychain from China. Dear Mr. Reel: In your letter dated April 2, 2015, you requested a tariff classification ruling. The submitted sample, SKU #2478, is described as a multi-function keychain. It consists of a metal key ring attached to a plastic frame that incorporates a metal bottle opener. The plastic frame can be folded outward and used as a cell phone stand. The bottom of the frame contains a pullout tray with an attached cloth that can be used to wipe a cell phone’s screen. The multi-function keychain is considered to be a composite good within the meaning of General Rule of Interpretation (GRI) 3. Goods classifiable under GRI 3(b) shall be classified as if they consisted of material or a component which gives them their essential character. The Explanatory Note to the Harmonized Tariff Schedule of the United States (HTSUS), GRI 3 (b) (VIII), states that the factors which determine essential character will vary between different kinds of goods. It may for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. Inasmuch as no essential character can be determined for the instant item, GRI 3(b) does not apply. GRI 3(c) states that when the essential character of a composite good cannot be determined, classification is based on the heading that occurs last in numerical order among those which equally merit consideration. In this case, the bottle opener falls last within heading 8205, HTSUS, in accordance with GRI 3(c). The applicable subheading for the multi-function keychain, SKU #2478, will be 8205.51.3030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: household tools, and parts thereof: of iron or steel: other (including parts): kitchen and table implements. The rate of duty will be 3.7% 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 Anthony Grossi at [email protected]. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division