The tariff classification of a lanyard and tin buttons from China.
Issued December 19, 2019 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 7117.19.9000, 7117.90.90, 9903.88.15
Product description
You provided two samples with your letter. The samples will be returned in accordance with your request. Item number 391703 is a strap lanyard of nylon woven printed fabric. The lanyard features a D ring to which a steel clasp and polyvinyl chloride (PVC) charm are separately attached. The PVC charm resembles three round orange slices configured to resemble the head and ears of Disney’s Micky Mouse character. The charm is approximately 3 inches x 2.75 inches. Item number 391705 is a tin button. The body of the button is made of tin, the pin is steel, and the design on the front of the button is printed paper and glued to the tin surface. It is sold as a set of five pieces. You have suggested classification of the lanyard, item number 391703, in subheading 6307.90.9889, Harmonized Tariff Schedule of the United States (HTSUS). However, since this lanyard is described and advertised as a product to be worn around the neck for adornment, it meets the definition of "imitation jewelry" as defined in Note 11 to Chapter 71, HTSUS. As such, it is specifically provided for elsewhere.
CBP rationale
The applicable subheading for the lanyard, item number 391703, will be 7117.90.90.00, HTSUS, which provides for “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Other. The applicable subheading for the tin buttons, item number 391705, will be 7117.19.9000, HTSUS, which provides for “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other.
Full text
N308119 December 19, 2019 CLA-2-71:OT:RR:NC:N4:462 CATEGORY: Classification TARIFF NO.: 7117.19.9000; 7117.90.90.00; 9903.88.15 Mr. Joseph J. Kenny Geodis USA Inc. One CVS Dr. Woonsocket, RI 02895 RE: The tariff classification of a lanyard and tin buttons from China. Dear Mr. Kenny: In your letter dated December 5, 2019, you requested a tariff classification ruling on behalf of your client, CVS Pharmacy Inc. You provided two samples with your letter. The samples will be returned in accordance with your request. Item number 391703 is a strap lanyard of nylon woven printed fabric. The lanyard features a D ring to which a steel clasp and polyvinyl chloride (PVC) charm are separately attached. The PVC charm resembles three round orange slices configured to resemble the head and ears of Disney’s Micky Mouse character. The charm is approximately 3 inches x 2.75 inches. Item number 391705 is a tin button. The body of the button is made of tin, the pin is steel, and the design on the front of the button is printed paper and glued to the tin surface. It is sold as a set of five pieces. You have suggested classification of the lanyard, item number 391703, in subheading 6307.90.9889, Harmonized Tariff Schedule of the United States (HTSUS). However, since this lanyard is described and advertised as a product to be worn around the neck for adornment, it meets the definition of "imitation jewelry" as defined in Note 11 to Chapter 71, HTSUS. As such, it is specifically provided for elsewhere. The applicable subheading for the lanyard, item number 391703, will be 7117.90.90.00, HTSUS, which provides for “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Other.” The rate of duty will be 11 percent ad valorem. The applicable subheading for the tin buttons, item number 391705, will be 7117.19.9000, HTSUS, which provides for “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other.” The rate of duty will be 11 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 7117.90.90.00 and 7117.19.9000, HTSUS, unless specifically excluded, are subject to an 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 subheadings 7117.90.90.00 and 7117.19.9000, HTSUS, listed above. 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 the 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, please contact National Import Specialist Sandra Sary at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division
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