The tariff classification of welding cable locks from China

N305865 September 10, 2019 CLA-2-83:OT:RR:NC:N1:121 CATEGORY: Classification TARIFF NO.: 8301.10.2000, 9903.88.15 Cayman L. Ellis KS Worldwide LLC 13507 Gulf Blvd Madeira Beach, FL 33708 RE: The tariff classification of welding cable locks from China Dear Mr. Ellis: In your letter dated August 19, 2019 you requested a tariff classification ruling. The samples you submitted have been examined and will be retained by this office for reference. The articles under consideration are described as the Leadlock and the Machinelock. Both articles have the same general design and are composed of the same materials. They are comprised of a PA6 plastic shell, two stainless steel pins in the hinges and a brass combination lock. The Leadlock weighs .9 lbs. and the Machinelock weighs .5 lbs. The padlocks, which function without a key, operate by way of three rotating numerical dials. The padlock in the Leadlock is 2.86 cm wide and the padlock in the Machinelock is 2.54 cm wide. Both articles are safety devices that securely connect welding leads thereby mitigating welding leads from arc outs, dropped objects and unauthorized use. The Leadlock is a device that locks and secures male and female welding lead connectors. A welding lead connector is inserted on either end of the plastic shell, enclosed and then locked in place with the padlock. The Machinelock is used for securing a welding lead to the welding machine. The machine is connected on one end of the plastic shell and a welding lead connector is inserted in the other end. The shell is closed around the connectors and then locked in place with the padlock. The applicable subheading for the Leadlock and the Machinelock will be 8301.10.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for padlocks and locks (key, combination or electrically operated), of base metal…Padlocks, not of cylinder or pin tumbler construction, not over 3.8 cm in width. The rate of duty will be 2.3 percent ad valorem. Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). See also “Notice of Action and Request for Public Comment Concerning Proposed Determination of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation” (June 20, 2018, 83 F.R. 28710). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings. Products of China classified under subheading 8301.10.2000, HTSUS, unless specifically excluded, are subject to the additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8301.10.2000, HTSUS, listed above. The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading. 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 Jennifer Jameson at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division