N351696

N351696 August 12, 2025 CLA-2-74:OT:RR:NC:N1:164 CATEGORY: Classification TARIFF NO.: 7419.80.5050; 7907.00.6000; 9903.78.01; 9903.78.02; 9903.01.32 Patrick Klein Neville Peterson LLP 55 Broadway, Suite 2602 New York, NY 10006-3744 RE: The tariff classification of rope clamps and snap hooks from multiple countries Dear Mr. Klein: In your letter dated July 25, 2025, you requested a tariff classification ruling regarding rope clamps and snap hooks from multiple countries on behalf of your client, Keystone Manufacturing and Supply, LLC. Product information was submitted with your request. The first items under consideration are described as rope clamps (model HRCB) from Malaysia, Taiwan, or Vietnam. During use, two strands of rope are inserted lengthwise through the center portion of the clamp to hold the ropes in a fixed and secured position. You state that the rope clamps are composed of brass (61% copper, 35% zinc, 4% other material) and measure 5/8 inches in inside width and 1 1/2 inches in overall length. The second items under consideration are described as snap hooks which will be used as connection hardware. Model 56B (from Malaysia or Vietnam) is composed of brass (61% copper, 35% zinc, 4% other material) and features a rectangular 1-inch eye, a 5/16-inch opening, and an overall length of 2 1/2 inches. Model 3726Z (from Taiwan) is composed of diecast zinc, with nickel finish, and features a rectangular 1-inch eye, a 5/16-inch opening, and an overall length of 2 1/2 inches. Based on the submitted information, both snap hook models feature a hook and a spring-loaded safety snap to prevent an item from escaping the inner surface of the hook. In your request, you suggest classification of the rope clamps in subheading 7419.80.50, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other articles of copper: Other: Other: Other. We agree. In addition, you proposed classification for the subject snap hooks under subheading 8308.10.0000, HTSUS, which provides for Clasps, frames with clasps, buckles, buckle clasps, hooks, eyes, eyelets and the like and parts thereof, of base metal, of a kind used for clothing, footwear, awnings, handbags, travel goods or other made up articles…: Hooks, eyes and eyelets. We disagree. Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989). First, Headquarters ruling 954696 (December 9, 1993) stated, in part, that snap hooks are not provided for eo nomine in any heading. As a result, further analysis is required. It is our determination that the subject snap hooks contain significant additional functionality that removes them from the generic term “hook” in the context of heading 8308 and places them elsewhere. In support of this conclusion, the ENs specifically exclude snap hooks from heading 8308 and specifically include them in the ENs to heading 7326, which provides for other articles of iron or steel. Although the snap hooks at issue are not of iron or steel, the ENs to headings 7419 (Other articles of copper) and 7907 (Other articles of zinc) make clear that both headings provide for articles of the types listed in the ENs to heading 7326. Section Note XV Note 5, HTSUS, states, in part, that an alloy of base metals of this section is to be classified as an alloy of the metal which predominates by weight over each of the other metals. Additionally, an alloy composed of base metals of this section and of elements not falling within this section is to be treated as an alloy of base metals of this section if the total weight of such metals equals or exceeds the total weight of the other elements present. Accordingly, the brass rope clamps and brass snap hooks, which are an alloy in which copper predominates over zinc and other unspecified materials, are classified as other articles of copper. The applicable subheading for the brass rope clamps (model HRCB) and brass snap hooks (model 56B) will be 7419.80.5050, HTSUS, which provides for Other articles of copper: Other: Other: Other: Other. The general rate of duty will be Free. The applicable subheading for the zinc snap hooks (model 3726Z) will be 7907.00.6000, HTSUS, which provides for Other articles of zinc: Other. The general rate of duty will be 3 percent ad valorem. On July 30, 2025, Presidential proclamation 10962 imposed additional tariffs on certain semi-finished copper and intensive copper derivative products. Additional duties for semi-finished copper and intensive copper derivative products of 50 percent upon the value of the copper content are reflected in Chapter 99, heading 9903.78.01. The non-copper content of these products, provided for in heading 9903.78.02, is not subject to the additional ad valorem duties. At the time of entry, for the copper content you must report heading 9903.78.01, in addition to subheading 7419.80.5050, HTSUS. For the non-copper content, you must report heading 9903.78.02, in addition to subheading 7419.80.5050. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Malaysia will be subject to an additional ad valorem rate of 19 percent, products of Taiwan will be subject to an additional ad valorem rate of duty of 20 percent, and products of Vietnam will be subject to an additional ad valorem rate of duty of 20 percent. Products classified in headings 7419.80.5050 and 7907.00.6000 fall in an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.32, in addition to subheadings 7419.80.5050 and 7907.00.6000, HTSUS. The tariffs and additional 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/. 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 (C.F.R.), 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 C.F.R. 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 merc

is required. It is our determination that the subject snap hooks contain significant additional functionality that removes them from the generic term “hook” in the context of heading 8308 and places them elsewhere. In support of this conclusion, the ENs specifically exclude snap hooks from heading 8308 and specifically include them in the ENs to heading 7326, which provides for other articles of iron or steel. Although the snap hooks at issue are not of iron or steel, the ENs to headings 7419 (Other articles of copper) and 7907 (Other articles of zinc) make clear that both headings provide for articles of the types listed in the ENs to heading 7326. Section Note XV Note 5, HTSUS, states, in part, that an alloy of base metals of this section is to be classified as an alloy of the metal which predominates by weight over each of the other metals. Additionally, an alloy composed of base metals of this section and of elements not falling within this section is to be treated as an alloy of base metals of this section if the total weight of such metals equals or exceeds the total weight of the other elements present. Accordingly, the brass rope clamps and brass snap hooks, which are an alloy in which copper predominates over zinc and other unspecified materials, are classified as other articles of copper. The applicable subheading for the brass rope clamps (model HRCB) and brass snap hooks (model 56B) will be 7419.80.5050, HTSUS, which provides for Other articles of copper: Other: Other: Other: Other. The general rate of duty will be Free. The applicable subheading for the zinc snap hooks (model 3726Z) will be 7907.00.6000, HTSUS, which provides for Other articles of zinc: Other. The general rate of duty will be 3 percent ad valorem. On July 30, 2025, Presidential proclamation 10962 imposed additional tariffs on certain semi-finished copper and intensive copper derivative products. Additional duties for semi-finished copper and intensive copper derivative products of 50 pe