The tariff classification of a wrist strap and a keychain from China

N363455
July 29, 2026
CLA-2-73:OT:RR:NC:CEE008:N1:113
CATEGORY: Classification
TARIFF NO.: 7326.90.8688
Vanessa Bracero The Jewelry Group, Inc. 1411 Broadway New York, NY 10018 RE: The tariff classification of a wrist strap and a keychain from China Dear Ms. Bracero: In your letter dated July 20, 2026, you requested a tariff classification ruling. Informational material was submitted with your request. The items under consideration are a wrist strap and a key chain. The wrist strap, style number PK2203, is identified as the “Live Love Bark Charm Wristlet Strap.” The keychain, style number PK2101, is identified as the “Cat Mom Carded Tassel Keychain.” The wrist strap consists of a steel chain 10 inches long joined together by a brass buckle with polyester webbing woven between the links. The strap is adorned with a single plastic pearl and four zinc dog themed charms hanging along the chain. The key chain consists of a steel key ring 28 millimeters in diameter with a brass chain holding two zinc cat themed charms and a decorative tassel made of polyester rope. The classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the General Rules of Interpretation (GRIs) taken in order. GRI 1 provides that “classification shall be determined according to the terms of the headings and any relative section or chapter notes.” Since no heading covers the subject articles in the tariff, GRI 1 cannot be used as a basis for classification. 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.” In the application of GRI 3(b), the components that give the essential character for each article is the steel chain for the wrist strap and the steel key ring for the keychain because these are the components that allow the articles function. The chain allows the wrist strap to be worn on the wrist, and the key ring allows the keychain to carry keys. With both components imparting the essential character and being composed of steel the wrist strap and the keychain are classifiable in Chapter 73, HTSUS, which provides for “Articles of iron or steel.”

Heading 7326, HTSUS, is a residual or basket provision which covers a wide range of iron or steel articles that are not more specifically provided for elsewhere in the HTSUS. The Explanatory Notes (ENs) to heading 7326 state that “This heading covers all iron or steel articles obtained by forging or punching, by cutting or stamping or by other processes such as folding, assembling, welding, turning, milling or perforating other than articles included in the preceding headings of this Chapter or covered by Note 1 to Section XV or included in Chapter 82 or 83 or more specifically covered elsewhere in the Nomenclature.” An article of iron or steel can be classified in heading 7326 if it is determined that the item is not more specifically provided for in any other heading of the tariff. The wrist strap and the keychain are not specifically covered elsewhere in the tariff. Accordingly, it is classifiable in heading 7326, HTSUS. The applicable subheading for the wrist strap, style number PK2203, and the keychain, style number PK2101, will be 7326.90.8688, HTSUS, which provides for “Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9 percent ad valorem. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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 Matthew Gay at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division