The tariff classification of the Sun Joe Handler System from China

N276743 July 14, 2016 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8466.10.0175 Mr. Charles Spoto Alba Wheels Up International, Inc. 1 E Lincoln Avenue Valley Stream, NY 11580 RE: The tariff classification of the Sun Joe Handler System from China Dear Mr. Spoto: In your letter dated May 10, 2016, on behalf of Snow Joe LLC, you requested a tariff classification ruling. The imported item is called a Sun Joe Handler System, model number SJ-HS101. The system is intended for the home gardener. It includes a 48 in. fiberglass handle, a steel blade shovel, a steel blade flat shovel, a push broom, a garden rake and a garage storage system. The handle consists of a fiberglass shaft and nylon locking tip mechanism with stainless steel ball bearings in order to create a durable design to withstand tough yard work. It is ergonomically designed to switch tools easily. The storage system provides space savings by keeping the tools securely stored and off the garage floor. Wall mounts securely fasten to a wall stud in the garage. At time of importation, the system is imported packaged for retail sale and nothing is added after importation. Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). The above described system is a set which consists of at least two different articles that are, prima facie, classifiable in different headings. It consists of articles put up together to carry out a specific activity (i.e., home gardening). Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the set in question is within the term "goods put up in sets for retail sale”. GRI 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. In this instance, the handle is necessary for the use of the tools. Among the components that merit equal consideration, it is the only component continually in use. For these reasons, it is the opinion of this office that the handle imparts the essential character to the set. By application of GRI 3(b), the applicable subheading for the Sun Joe Handler System, model number SJ-HS101, will be 8466.10.0175, HTSUS, which provides for “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for machine tools; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Other”. 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 https://hts.usitc.gov/current. 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 Patricia O’Donnell at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division