Jan. 29 CBP Bulletin Revokes Rulings on Hole Saw Kits and Aquadoodle Products
The Jan. 29 issue of the CBP Customs Bulletin (Vol. 48, No. 4), CBP published two notices of revocation of rulings and treatment regarding hole saw kits and Aquadoodle products.
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Revocations Are Effective March 31
CBP is revoking these rulings, as well as any treatment CBP previously accorded to substantially identical transactions, effective for merchandise entered or withdrawn from warehouse for consumption on or after March 31.
Saw Kits
| Item: Hole Saw Kits. The kits include six hole saws, two mandrels with steel pilot drills, one threaded mandrel adaptor and a fitted carry case. The mandrels are attached to and inseparable from the pilot drills. The mandrels are simply used to fit the hole saws to the pilot drill bits. As such, the mandrels are essentially extensions to the bits. The pilot drills are twist drills. The cutting parts of the hole saws and the pilot drills are made from M3 High Speed Steel. The kit is used to cut holes through drywall, wood, plastic and metal. |
| New Ruling: HQ H097658 (dated 01/07/14), revokes NY N090938 (2010) |
| Old HTS/Rate: 8207.50.2055, 5% (Interchangeable tools for hand tools, whether or not power operated, or for machine-tools (for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or screwdriving), including dies for drawing or extruding metal, and rock drilling or earth boring tools; base metal parts thereof: Tools for drilling, other than for rock drilling, and parts thereof: With cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium: Twist drills: Other) |
| New HTS/Rate: 8202.99.00, Free (Handsaws, and metal parts thereof; blades for saws of all kinds (including slitting, slotting or toothless saw blades), and base metal parts thereof: Other saw blades, and parts thereof: Other (including parts)) |
| Reason: CBP previously found that the hole saws and mandrels gave equal character to the kits. CBP now says the primary purpose of the hole saw kit is to cut holes through drywall, wood, plastic, and metal. Insomuch as the hole saws are integral to the activity of cutting, the hole saws are indispensable to the condition of the merchandise. Consequently, CBP now find that the components which impart the essential character of the hole saw kit are the hole saws |
(See 12082032 for summary of the proposed revocation of this ruling.)
Aquadoodle Draw And Doodle
| Item: Aquadoodle Drawing Toys. The Aquadoodle products are textile fabric mat packaged with two marker pens that are intended to be filled with water before use and used by children. When the water-filled pens touch the mat, the water causes the mat to change color so that a child can write or draw on the mat without making a mess. When the water dries, the marks on the mat disappear and the child can draw on a clean mat again. |
| New Ruling: HQ H236028 (dated 01/07/14), revokes HQ W968020 (2006), HQ H050118 (2010), NY N091640 (2010), NY R03958 (2006), and NY L885729 (2005) |
| Old HTS/Rate: 6307.90.9889, 7%, ([o]ther made up articles, including dress patterns: [o]ther: [o]ther: [o]ther: [o]ther: [o]ther.)) |
| New HTS/Rate: 9503.00.00, Free, (Tricycles, scooters, pedal cars and similar wheeled toys; dolls’ carriages; dolls, other toys; reduced-scale (“scale”) models and similar recreational models, working or not; puzzles of all kinds; parts and accessories thereof…) |
| Reason: Aquadoodle products are sold by toy stores and in the toy department of stores, which indicates that the toy industry recognizes Aquadoodle products as toys. The water pens and mat are considered to be parts, as neither item could function properly without the other. |
(See 13071220 for summary of the proposed revocation of this ruling.)