BURTON, KRISTOPHER If he can't guess by this title slide,
I'm national import specialist Christopher Burton.
BURTON, KRISTOPHER I handle a. Let's see.
Heading 3406 for candles, parts of heading 3926,
which is other articles of plastic.
Not all of 3926, just some of it.
BURTON, KRISTOPHER Umm all of chapter 67.
BURTON, KRISTOPHER Maybe I'll say it's artificial foliage
a half the the second-half of chapter 82.
BURTON, KRISTOPHER And the forks, knives and spoons.
And we I have heading 8516, which is the domestic electrothermal compliances
and then a smattering of headings in Chapter 96
to mainly include the brushes, Combs, hair slides.
You may have seen those in past presentations.
BURTON, KRISTOPHER So if you have any questions or need
to be addressed after the fact, you can always e-mail me.
My e-mail is right there.
I should also have my e-mail on the closing slide.
So in that case there we go.
BURTON, KRISTOPHER So I'm gonna go ahead and I'm also
to maybe help a little bit with network connectivity.
My turn my camera off.
I'll be here the entire time, so let's go.
BURTON, KRISTOPHER First, a few of the other items that we have to do,
the CBP mission state, then we are here to protect the American people,
safeguard our borders and enhance the nation's economic prosperity.
And we are part of the Office of Trade.
BURTON, KRISTOPHER And in their statement
as the Office of Trade facilitates limit trade, it forces US laws
and protects the American economy and ensure consumer safety
and to create a level playing field for American businesses.
BURTON, KRISTOPHER A little disclaimer.
BURTON, KRISTOPHER Essentially, I'll summarize it if you wanna read it,
that's fine, but we're going to be speaking about the general rules
of interpretation.
Some of it may be personal opinion, some of it, you know, hey, we all,
we're all human, we I might misspeak.
I might say something that's not wholly accurate.
BURTON, KRISTOPHER I'm relying solely on what I say.
It would not be considered reasonable cares,
so if later down the road you say, well, and I ask, Burton said.
BURTON, KRISTOPHER You know during this presentation and you might be
in trouble with that.
So just just be mindful that I'm doing my best to inform you guys
about general rules and you know.
BURTON, KRISTOPHER Have that little grain of salt there just in case.
BURTON, KRISTOPHER This one, uh, just another disclaimer
about the audio visual.
BURTON, KRISTOPHER I just say that most of them were taken
from the Internet thanks to Google.
BURTON, KRISTOPHER You know they're.
BURTON, KRISTOPHER Most of my, let's say general representations of products
that I'm trying to.
BURTON, KRISTOPHER Describe and no way is anything, you know,
biting on a specific product.
BURTON, KRISTOPHER Then last one, this is also a pitch for E rulings.
That classification I mean if you classified for any time at all,
you know it's complicated, it's very subjective.
BURTON, KRISTOPHER Please consult either last customer, broker, attorney,
consultant or yes, it's a free service.
The airlines thing you send us,
your product information will write up a body.
Really love letter and get you a more definitive classification
just as another heads up.
As far as the e-mail me or ask in this meeting.
Hey, how do you classify product X?
Unfortunately I cannot provide you a classification through e-mail or.
BURTON, KRISTOPHER So this means I can give you general guidance
on how we would go about classifying it,
but I can't say well the classification is.
BURTON, KRISTOPHER Centers.
BURTON, KRISTOPHER OK.
With that, we are going to start with the general rules of interpretation.
BURTON, KRISTOPHER Make sure that things are working.
BURTON, KRISTOPHER If you guys wanna go ahead and start with a chat box,
which gear ride do you think you use most?
BURTON, KRISTOPHER To see what people think.
BURTON, KRISTOPHER You have it just a couple of seconds.
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER Right now I'm seeing pretty much a consensus of one
with a sprinkling of three.
BURTON, KRISTOPHER I guess in a way this could be a trick question.
BURTON, KRISTOPHER Is unless you classify everything
at the heading level.
BURTON, KRISTOPHER You also use fix and you probably use six just about
as much as you use one.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER Just as a heads up again
and I'll reiterate this multiple times, when we go
through the run the first time, it's all at the four digit heading level.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER OK, this is the actual text of Jerry one.
BURTON, KRISTOPHER Basically says table contents have better index titles
and sections.
Chapters of chapters were provided for ease of reference only.
BURTON, KRISTOPHER Now that is a reference only for legal purposes,
classifications determined according to terms of the heading
and the relative section and chapter notes.
BURTON, KRISTOPHER So for those that.
BURTON, KRISTOPHER Maybe newer classification
or those that have done it
for so long, they've forgotten some of the basics.
BURTON, KRISTOPHER This is how I was taught
how to classify is you have your ruler or straight edge.
You start at that heading level.
So in this case 6702 with the artificial flowers, foliage and fruit.
BURTON, KRISTOPHER And then he worked down.
So say you have an artificial flower.
BURTON, KRISTOPHER What to say?
Or I'll I'll go with something easy a second, like made of plastic so.
BURTON, KRISTOPHER We got getting 6 to 7.
Two you drop in, is it uh, plastics or of other materials?
It's a plastic circulant and it's made by, you know, gluing together.
So then we can go.
OK, check.
So we go in to 6702 ten.
BURTON, KRISTOPHER And then as it assembled by by including
or similar methods check I said it was glued together so then one tick in
and then you compare as you go down.
So 4 digit to 4 digit, 6 digit to 6 digit 8 and 10.
BURTON, KRISTOPHER No, just a little trick there.
BURTON, KRISTOPHER But it it even happens to me.
You see something down there?
BURTON, KRISTOPHER And we'll just say of feathers.
Hey, I have something of feathers.
BURTON, KRISTOPHER While his it, you know artificial fruits college
because 6701 is actually articles of feathers so.
BURTON, KRISTOPHER You can be.
Oh, hey, I have something feathers and you just see that there
and you're not looking at the heading language.
Sometimes subheading language contribute up.
You can have exactly what you're looking for at the subheading,
but we don't pass about the subheading you have to start at the heading level
and work your way down.
BURTON, KRISTOPHER I'm going to go through the explanatory notes.
BURTON, KRISTOPHER And I just kind of pick out some of the main things,
hopefully repeat them the, you know, requisite three times, so it sticks.
BURTON, KRISTOPHER Again, the language and section chapters
and subchapters are given there to kind of organize things,
but you need you can't rely on them specifically for classification.
BURTON, KRISTOPHER And as as mentioned again.
BURTON, KRISTOPHER Those titles are for reference only.
BURTON, KRISTOPHER And accordingly for Jerry, I want to work.
BURTON, KRISTOPHER Things will be classified according
in terms of the headings and the relative section or chapter notes.
BURTON, KRISTOPHER And that's of course, yeah, you have to go
to the later rooms.
BURTON, KRISTOPHER For the most part, and that's why, you know,
I would say that, you know, minus the little caveat about Jurassic,
that GRI one is what we use pretty much all the time.
BURTON, KRISTOPHER Jerry three is probably the one we argue the most over,
but here I won is where it's specifically named,
and sometimes it's very clear what it is.
On the example they provided live horses and 101.
I'll just another little disclaimer and some of the stuff that it mentions.
I do not cover.
I will just kind of read it as what's provided.
But if you have questions on like horses or pharmaceutical goods
or some of the other things that pop up, I I can't go with.
I can't help you with.
BURTON, KRISTOPHER So OK.
BURTON, KRISTOPHER And then just says a little carve out.
BURTON, KRISTOPHER For reference, according to provisions, 2345 means that
if you have those that are presented incomplete or unfinished,
we'll get to that with two and on a simple also with and.
Yeah, there it says, provide the terms of two are satisfied in the headings
or nodes do not otherwise required.
BURTON, KRISTOPHER So what do I need to know?
BURTON, KRISTOPHER Again, titles of sections, chapters and subchapters are
for use of reference only.
BURTON, KRISTOPHER Classification shall be termed according to terms
of the heading and any relative section or chapter notes.
BURTON, KRISTOPHER And last, the headings
and any relative section chapter notes are paramount i.e.
There the first consideration enter determining classification build saying
about apples and oranges and Apple is an apple.
Apple is not an orange.
So if you're say have an apple to classify, you're classified as an apple,
not as.
BURTON, KRISTOPHER Another piece of but again can't handle fruits.
So just an example.
This I do handle so it is a candle and is this classified using Jiri one
in the chat box.
Just a little yes or no will do.
BURTON, KRISTOPHER Catching quite a few yeses.
BURTON, KRISTOPHER And and I'm.
I'm sorry.
I I didn't.
I didn't give you the the actual tariff that's on the next slide
because that would make it a little too easy because.
BURTON, KRISTOPHER Yes, candles are classified at the head level
and at the sub heading level.
This is one of the few where you can actually do this, just GRI one
because it's 3406 done now.
I mean, I guess at the full you know 10 digit you are gonna use your I 6
but 34 six is candles.
So that's a pretty easy one.
BURTON, KRISTOPHER Now, there are some candles
that aren't classified there, and that's where you have
to get into the notes and other relevant say.
Not all candles bond or 34 to 6, but.
BURTON, KRISTOPHER The the bulk, that's where the good.
BURTON, KRISTOPHER OK, now what about this?
This is a triangular, triangular reflective Rd sign.
BURTON, KRISTOPHER Yes or no.
BURTON, KRISTOPHER Here I want.
BURTON, KRISTOPHER OK.
Yeah.
I guess I'm seeing people with the.
BURTON, KRISTOPHER A slow turnover.
Just give it a second.
BURTON, KRISTOPHER OK, well, since people are having some issues
with getting from the candle slide to the.
BURTON, KRISTOPHER Our reflective Rd sign.
It is a bright orangy red reflective plastic.
It's made of plastic slide.
BURTON, KRISTOPHER All of my presentation.
BURTON, KRISTOPHER Taking it back.
BURTON, KRISTOPHER Should be back to.
BURTON, KRISTOPHER What about this product?
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER How's it going now?
We're good.
BURTON, KRISTOPHER Yeah, I should be on site 17.
BURTON, KRISTOPHER So we had the horse.
BURTON, KRISTOPHER Slide 15.
BURTON, KRISTOPHER I went over the candles with heading 3406.
BURTON, KRISTOPHER And now we have the triangle.
I'm seeing a lot of thumbs up, so hopefully that will work,
but we'll go with that.
BURTON, KRISTOPHER So OK.
BURTON, KRISTOPHER Sorry everyone.
BURTON, KRISTOPHER Love technology.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER Are we sure I won with this product?
BURTON, KRISTOPHER And so I guess if you can go ahead, just ask you don't.
BURTON, KRISTOPHER The.
BURTON, KRISTOPHER And I guess cheat, since you can skip ahead.
But for this one the answer is sort of.
BURTON, KRISTOPHER So yes, technically you do use your one
to classify a reflective triangular warning sign for Rd use.
BURTON, KRISTOPHER But you have to use GRI six first to get there.
So you started heading 3926 as another article Classic under GR1
and then you using your ruler you just kind of trickle down
and there you go.
BURTON, KRISTOPHER But.
BURTON, KRISTOPHER As, as I said, say this is plastic and metal.
BURTON, KRISTOPHER You say your reflective triangular warning sign
for Rd use.
BURTON, KRISTOPHER Well, it may or may not be classified here depending on
if it is a composite good and if it's a composite good,
then of course you know we'll trickle to three, but.
BURTON, KRISTOPHER You would have to compare 3926
and the other heading sag could.
BURTON, KRISTOPHER Umm.
Include the composite code.
BURTON, KRISTOPHER So just because you see something
that's very specifically named or reflected triangular warning sign
doesn't mean necessarily that's where all reflective triangular warning
sense code.
BURTON, KRISTOPHER Now I'm going to go JIRA one sets.
BURTON, KRISTOPHER Like 19.
Hopefully everyone can see that now and this is a little.
BURTON, KRISTOPHER Unique item I do handle two of them.
There's a handful of them throughout the tariff, think there's a a chunk
of them in the tech styles group and then I know there's one or two earlier
in chapter 82.
Essentially what this is, it's a set that's named in the Terra.
So instead of having to get to R3 and saying, hey, what does this consist of?
BURTON, KRISTOPHER Is specifically named, though I would read it to state
that you have to have some of the similar features
of a set you know retail packaging, different classifications.
If you say for the 8211.
BURTON, KRISTOPHER If you have.
BURTON, KRISTOPHER Or steak knives package together.
BURTON, KRISTOPHER Not sure that it would go there.
BURTON, KRISTOPHER I would have to do some more research.
This is one of those.
That's my opinion.
BURTON, KRISTOPHER For part of that.
But you know, I would say it says asset.
BURTON, KRISTOPHER If you just have the pork steak knives,
they all hold the same classification so.
But typically when we see these we see.
BURTON, KRISTOPHER The steak knives, the you know, kitchen knives,
the scissors, the wood block, the sharpener.
BURTON, KRISTOPHER The other one is an 8215.
This is essentially your flatware sets, the forks, knives and spoons.
BURTON, KRISTOPHER And you'll notice that on both cases,
the rate of duty is not provided.
It's not, say, 5%, it's the rate of duties to have equal to the article
in the set, subject to the highest rate of duty.
BURTON, KRISTOPHER And how do you figure that out?
BURTON, KRISTOPHER Well, here is a quick overview
of how to calculate the ad valorem equivalent rate.
I use headquarters ruling 967248 from 2004.
BURTON, KRISTOPHER I am aware that there is a formula
in the ICP for cutlery.
It is slightly different but at least from my experience.
BURTON, KRISTOPHER The answer may be slightly different or the number answer,
but you will come out with the same highest rate for the item.
BURTON, KRISTOPHER So to convert a compound duty rate to equipment one,
again the unit value of each article.
So for those that submit, binding rulings for anything
in eighty 8211 or 8215.
BURTON, KRISTOPHER Please include the value of each item
so then that way we can use this to calculate.
BURTON, KRISTOPHER Then we apply it to the compound rate of duty.
BURTON, KRISTOPHER So in here.
BURTON, KRISTOPHER Yeah.
The specific rate, say $0.03 plus that bolorin rates
of 3.2 per percent times the unit value, say about 50 and then you'll end up
with a duty amount.
Then you round to the nearest cent.
That's very important that if you're using Excel,
there's the feature called round which will help round,
otherwise it will calculate how infinitely
and it can throw your numbers off a little bit.
BURTON, KRISTOPHER Umm.
BURTON, KRISTOPHER Then grew out divided
by unit value equals your clever rate.
There is section 301 duties, at least for right now.
BURTON, KRISTOPHER Umm that have to be considered when calculating
which has the highest rate and that's to get your total comparable rate
is equal rate plus.
BURTON, KRISTOPHER Section 31.
Duties.
BURTON, KRISTOPHER Have a previous presentation.
I got a question.
Do anti dumping duties counting this?
No anti dumping duties are separate.
Those fall under commerce where the section 301 duties are actually
in Chapter 99 of the tariffs.
So you have one through 97 and then chapter 99.
So they're all within the Terra for calculating the duty rates.
BURTON, KRISTOPHER And here's the rest of the.
BURTON, KRISTOPHER The ruling kind of explaining how they went
about calculating that it's just kind of an example of.
BURTON, KRISTOPHER Yeah.
This together at that together.
BURTON, KRISTOPHER That proportionally,
it you had to do some math though.
If you're handy in Excel, you can create a template.
BURTON, KRISTOPHER I'm using formulas in Excel and then you just have
to plug in the different rates.
I will point out because it does that too is in the tariff.
You'll see like .7 cents.
BURTON, KRISTOPHER That's less than one cent,
so for calculation purposes it's not .07, it's .007.
So just as an that accent is .0 something,
and then if you're under that, then you have to actually go .00.
BURTON, KRISTOPHER Just a little thing.
BURTON, KRISTOPHER OK.
And then one last will bet on Jared onsets, again, if you follow the news,
he's could go away at any time or stay on, don't know.
So we'll just keep going on is that if you have a GRI once set
and I believe both 8211 and 8215 have at just at the heading level.
So let me go back just to show you.
BURTON, KRISTOPHER So if you go to here and 1616 is.
BURTON, KRISTOPHER And here the.
BURTON, KRISTOPHER Sets the jury one set provision as 301 duties
if the component.
BURTON, KRISTOPHER That that provides the highest rate of duty.
BURTON, KRISTOPHER Just say that a knife steak knife
has a section 301 duties.
You take the component value if none of the components have section 31 duties,
then you just stick with the the straight duty provided by.
BURTON, KRISTOPHER Uh, Jerry, once that sorry.
BURTON, KRISTOPHER And if you have.
BURTON, KRISTOPHER A component.
Then you use one of these other subheadings and the component provide.
So say you had at the the heading level or the Jerry.
Once that level 25% in the component had 25%.
It's not 50% duty.
The component has 25%, so it's just 25%.
BURTON, KRISTOPHER Or if it's on this floor,
so say the the the subheading Geri once set has 25%, the component has 7.5%.
BURTON, KRISTOPHER Congratulations, you're now at 7.5% for the whole year.
I once set.
BURTON, KRISTOPHER OK.
And I will open up for just a couple of questions.
BURTON, KRISTOPHER Umm.
BURTON, KRISTOPHER If you may have them before I go on to J R2.
BURTON, KRISTOPHER Just as a little side
to your I2 and some of these others,
I will not focus as much on because they're lesser used
and some of the other.
BURTON, KRISTOPHER Well, I guess some of
some of the features are more suited for other commodities.
BURTON, KRISTOPHER OK, So what was the ruler thing again?
BURTON, KRISTOPHER Let me go back.
BURTON, KRISTOPHER So the ruler is where you take the straight edge
of the ruler and you just work in.
So you start at artificial flowers, foliage, fruit.
So that's the first line with the ruler.
And then when you tick in, you go in 6 digits.
So then you're comparing of plastics and of other materials.
So say you have an artificial flower that isn't a plastics.
Well, it's not a plastics that you go down to of other materials
and then you take the ruler in when we're time well is it?
BURTON, KRISTOPHER A feathers.
BURTON, KRISTOPHER Yes.
Now if it's now, you go down to other demand made fibers.
BURTON, KRISTOPHER Yes.
Now go down to others.
So that's the ruler trick where you just kind of keep pushing in
and asking the question.
Yes.
No.
And if it's yes, you stop.
If it's no, you go down to the one below.
BURTON, KRISTOPHER 2.
BURTON, KRISTOPHER OK.
So question is the difference between a heading and subheading.
BURTON, KRISTOPHER Yes, it goes from left to right in.
BURTON, KRISTOPHER Let me just go back to that slide so.
BURTON, KRISTOPHER That will be.
BURTON, KRISTOPHER OK, so for everyone the difference?
BURTON, KRISTOPHER At the very top
and I did cut this off is you have chapter so say this is in chapter 67.
I unfortunately I do not recall the section, but there's the section
which chapters fall into which are grouped together
and then you have chapters.
So this is chapter 62.
Then the four digit is what we call the heading level.
So 6702.
BURTON, KRISTOPHER Is the heating.
BURTON, KRISTOPHER Or, you know, with other artificial plastic 3926
four digit that is the heading.
BURTON, KRISTOPHER And then once you go in passport digits.
BURTON, KRISTOPHER So when you get to 67 to 210, that's now subband.
So you have the six digit submitting.
BURTON, KRISTOPHER You have the 8 digit subheading
and then you have you add the statistical
with the the 9th and 10th digit.
So then you'll actually have.
BURTON, KRISTOPHER The 10 digit statistical subheading,
which is typically where you find the tree rings,
sometimes the duty rates a little bit higher up,
but a lot of times it's at the full 10 digit said you get the duty rate.
BURTON, KRISTOPHER But yes, as as saying you go.
BURTON, KRISTOPHER Deer tick and then in to the right tick and tick.
BURTON, KRISTOPHER And that's how you go there.
So I'll put that answer those questions.
BURTON, KRISTOPHER Two, this is in a way a kind of version
of a I guess you could say it's a broken out version of July 1, so you have.
BURTON, KRISTOPHER A on any reference to an article is.
BURTON, KRISTOPHER As long as it meets the you know character
of a completed article, if it's presented incomplete, unfinished.
BURTON, KRISTOPHER It can be classified as that article, so in a way.
BURTON, KRISTOPHER If if you have something
that's just simple disassembly,
you can classify it as if it's the whole article.
BURTON, KRISTOPHER And then, sure, I too can you reference the heading
to a mixture substance shall be taken to include a reference
to mixtures or combinations of the material
as it's kind of explained to me,
this is more of a gateway to get the Rule 3,
but I guess there are some very small.
BURTON, KRISTOPHER Uses of this my closest one that I could think
of could be wrong, but was that Unicorn candle?
If you notice it's horn was metal, it actually had.
If you burnt it and melt down it had like metal skeleton.
BURTON, KRISTOPHER It is, in a way, a composite good.
You have wax and metal.
BURTON, KRISTOPHER But it's a candle, so in a way, you're I2B could expand it
to say, even though yes, you have the wax and the metal, it's a candle.
So we're gonna just classify this candle.
BURTON, KRISTOPHER OK.
And complete.
BURTON, KRISTOPHER Or unfinished articles extends the scope
of adding refers to a particular articles
to cover not only the complete article
but also the article incomplete or unfinished provided that.
BURTON, KRISTOPHER As presented, it has its central character
of the complete work finished article.
BURTON, KRISTOPHER Umm, it does?
Explanatory notes go to into blanks.
BURTON, KRISTOPHER Because I don't really handle the the pre manufacturer,
I do maybe with the manufacturer.
That's all kind of skip that, but it is there for you reference.
BURTON, KRISTOPHER Thanks.
BURTON, KRISTOPHER Incomplete or unfinished in the view of the scope
of the headings section one through six are the rules.
Does not normally apply to the goods of the section,
and there are some exclusions on for some of the chapters.
BURTON, KRISTOPHER The below picture is kind of an example.
BURTON, KRISTOPHER And maybe not the best example, but you have
in this case like a Dyson hair grab that's completely disassembled.
If this all came together and all you really had to do was kind
of screw some stuff together, this is kind of a example.
Rough example of what, like an unfinished article,
and it's pretty much there.
You can tell it's gonna be a hair dryer.
It's just not all the way there.
BURTON, KRISTOPHER On assembled disassembled.
BURTON, KRISTOPHER The noted I do not handle furniture,
but I thought this would be the easiest.
If anyone has gone to any of the stores or ordered any furniture online
that's shed shipped flat packed where everything is taken apart
and then you have to, you know, get out your hex wrench
and put all those screws together to build desk the bed, the table.
BURTON, KRISTOPHER Whatever it may be, that is a very good example
of being presented on assembled or disassembled is.
BURTON, KRISTOPHER You know this image.
It's a bed.
BURTON, KRISTOPHER It just will come to you in a box unassembled
and you just have to put in all the screws and now you have a bed.
So it would be classified as a bed.
But more than that, I will defer to the NIS that handles the furniture.
BURTON, KRISTOPHER So again, just two way expanded.
BURTON, KRISTOPHER Arcsin uh, similar to symbol means articles,
ones which are two misspelled, either by means of fixing devices.
As I said, screws, nuts, bolts, etcetera,
or by riveting or welding for example,
provided only assembly operations are involved.
BURTON, KRISTOPHER Add to advance it anything further.
BURTON, KRISTOPHER No counter would be taking the regard.
The complexity of assembly method.
However, the component shall not be subject to any further working operation
for completion into the finished state.
BURTON, KRISTOPHER Unassembled components of an article which are
in excess of the number required for that article when complete,
are to be classified separately.
So.
BURTON, KRISTOPHER I'm trying to think if you had that flat packed.
BURTON, KRISTOPHER A piece of furniture.
And then you had.
BURTON, KRISTOPHER A whole bunch of extra.
BURTON, KRISTOPHER I was attacked the rollers.
BURTON, KRISTOPHER OK, some something else that will go
in that those not use that then you would have to break it out
until you'd have two items.
BURTON, KRISTOPHER Make sure some combinations.
Again, I do not handle this that much, so I can't speak as well to mixtures
and combinations, but my research.
BURTON, KRISTOPHER What?
They just, I guess kind of falls more into the food area.
Cereal was a great example I saw of like a mixture combination
where you have your Captain Crunch and you have your crunch berries
and they're mixed together and it's become one item.
BURTON, KRISTOPHER Or I'll make sure it's and combinations.
BURTON, KRISTOPHER I'm going to kind of get through through that.
So what do you need to know for sure I 2.
BURTON, KRISTOPHER Umm to a, which is I'd say of the Geri Twos 2A is the.
BURTON, KRISTOPHER So the extra not some, both the bed might
because everything shipped together.
I would say it depends.
BURTON, KRISTOPHER And you know, like it's one of those kind
of discretion things, if you have one or two extra nuts
or I'm say it's like the little screw in things that could be damaged
when during installation.
So you add you know two or three extra because the user damages them
and still needs them.
I would probably say that still be classified together.
BURTON, KRISTOPHER Umm.
BURTON, KRISTOPHER But as I said, if it's much more than that,
you have like a whole other half of a piece
of furniture put together and it's,
you know, it's so you can't just dump a whole bunch of stuff together and say,
ohh yeah, it's that it has to all be kind of put together as the one unit.
So yeah, if you have a couple extra screws.
BURTON, KRISTOPHER I probably would say that, but again I would have
to defer to.
BURTON, KRISTOPHER People that handle the furniture.
BURTON, KRISTOPHER So back to that extend the scope of the heading
which first a particular article to cover, not on the complete article,
but also article in its incomplete or unfinished state, provided
that is presented, it has essential character of the complete
or finished article.
So another example that we used fairly frequently.
So bicycle see the bicycle, it's going to be a bicycle and has that character.
It's not just some metal tubing and maybe a rubber hose
to make a tire you you know it's been assembled or bit.
BURTON, KRISTOPHER To be a bike.
So it's one of those with the central characters.
Sometimes you see, you know it when you see it.
BURTON, KRISTOPHER I'm articles presented on simpler disassembled means.
Articles with the command switch to be assembled by means of fixing screws,
that's false, etcetera.
BURTON, KRISTOPHER That to be simply extends the heading to include.
Make sure some combinations.
BURTON, KRISTOPHER Umm.
BURTON, KRISTOPHER Just.
BURTON, KRISTOPHER And of course Gateway 2.
BURTON, KRISTOPHER Rule 3.
So here we have a knife blade that does not have a handle.
As you can see it has a 2 little holes in it, so you would take
so in the Tang you take a wooden plastic rubber.
I'll probably not rubber click fold it on, but we'll say plastic
or wooden handle and you'd have your little bolts.
You'd put that on there and today you'd have a finished, right?
So this classified as 2A as an incomplete article.
BURTON, KRISTOPHER You're one of a couple of seconds to fill in.
BURTON, KRISTOPHER So not a lot of guesses.
BURTON, KRISTOPHER So this is where you have to go back to the chapter
or yeah, chapter and heading notes.
BURTON, KRISTOPHER And here.
BURTON, KRISTOPHER B.
BURTON, KRISTOPHER Any language knives?
BURTON, KRISTOPHER It's not life yet, and blades and other base materials,
so we have a knife blade.
So at the heading level 8211.
BURTON, KRISTOPHER You it provides for knife blades.
BURTON, KRISTOPHER If you go down a little bit further, it said the ruler,
other blades nice having fixed blades.
There we go it.
BURTON, KRISTOPHER That that might play does not folding into a handle,
or shouldn't, at least from the appearance.
BURTON, KRISTOPHER So now it's a year I won under 8211.
BURTON, KRISTOPHER So again, that might have been a little tough
if you didn't know about Nightblades, but that's just to be aware,
to check all the headings prior to.
BURTON, KRISTOPHER Jump into something else
because it may be yes, it is 6
to get to the actual classification, but at the heading level A211 does provide
for 9.
BURTON, KRISTOPHER OK, with that?
BURTON, KRISTOPHER Well, let's look at the time.
I'm gonna keep moving on, especially since Tuesday.
Not that special.
Well, it is special, but not as three.
I know everyone loves Yuri.
Three.
As I said, this is where we all argue about GRI 3A.
BURTON, KRISTOPHER Essentially, go with what's more specific bees probably
where all the fun happens, where you have the retail sets or well,
just say the sets and you have determines which character and then 3C,
which is also kind of fun, which is the coin flip.
And you go last interior.
BURTON, KRISTOPHER Well, this rule provides 3 messages
for classifying goods which are less valuable under two or more headings.
That's one of the things you need on the to be or any other reason.
This method operate in order, which says they are set out in the rule.
BURTON, KRISTOPHER Broken only take effect pride the terms of headings
or section or chapter notes do not otherwise require.
BURTON, KRISTOPHER But then they get some examples of some items that.
BURTON, KRISTOPHER Fallout with that?
So three a first method.
BURTON, KRISTOPHER I provides under the heading that's must Pacific
to the good generally.
If you've already made it down to three.
BURTON, KRISTOPHER You're probably going to skip 3A and end up in 3B,
but they do have an example of shavers and hair Clippers.
The self-contained electric motors.
It could go to either 8510 or 8467.
BURTON, KRISTOPHER Umm for working in the hands or 85 nine but.
BURTON, KRISTOPHER They say you know which one is the most specific, sorry.
BURTON, KRISTOPHER So you go with the shavers and hair Clippers,
which is more specific than a tool for working in the hand with the motor.
BURTON, KRISTOPHER And much like classification general,
it's not practical.
Lay down hard pass rules determine 1 heading.
You just have to case by case basis.
Study all the.
BURTON, KRISTOPHER Components and then make your best.
BURTON, KRISTOPHER Termination.
BURTON, KRISTOPHER And here it shows about less complete tough
to text out carpets identifiable for use of motor vehicles are not
to be classified as accessories to murder cars and assimilate,
but instead as carpets in 5703.
BURTON, KRISTOPHER So the explanatory notes are good
about providing some general examples of what they mean.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER As the yellow brick road implies,
we're gonna keep on going down to see the Wizard of 3B.
BURTON, KRISTOPHER That specific and you have multiple components.
BURTON, KRISTOPHER See the CAP has to say again.
Description by name is specific than description by class.
BURTON, KRISTOPHER And so make sures pause it.
Goods consisting of different materials, composite goods of different components
and goods, put up insets for retail sale.
BURTON, KRISTOPHER I would say from what I see, four the goods put up
and sets for retail sales probably where most of my time would be spent.
BURTON, KRISTOPHER Then maybe followed by.
BURTON, KRISTOPHER As the gods of different materials
and then different components.
BURTON, KRISTOPHER As I said, don't do much with mixtures.
I'm rule 3B and All in all these cases, goods would be classified
as that they consist of the material component
which gives them their essential character so much as criterion.
Some appeal the factor which determines the central character will have very
as between different kinds of goods.
It may for example, be determined by the nature of the material or component
in its bulk quantity waiter value, whereby the role
of the constituent material relation to the use of the goods.
BURTON, KRISTOPHER I'm waiting value or bulk quantities
of the sometimes I say quantity, weight or value is some of the things
that we look for in our rulings to make these calls.
They're not definitive.
That said, you could have something of lesser weight and lesser value,
but it provides the ultimate utility of the product
and it would not function without that.
And so even though it may have a lesser weighted value,
it can provide the essential character.
BURTON, KRISTOPHER Another one that I use, especially
with the decorative items, is a visual interest or visual impact
and when you look at a product you're like, wow, I see.
BURTON, KRISTOPHER You know the the flowers.
I see the bright yellow flowers and so.
BURTON, KRISTOPHER That may be a factor to use
in determining such a character.
BURTON, KRISTOPHER So here's some examples.
BURTON, KRISTOPHER Of.
BURTON, KRISTOPHER Different components adapted to one another.
BURTON, KRISTOPHER The good for the purpose of composite goods.
BURTON, KRISTOPHER And just as a note, composer goods made-up
of different components should be taken to mean not only those
in which the components are attached to each other
and form a practically inseparable from each other to form a practicable yes.
I repeated that all, but also those with several components.
BURTON, KRISTOPHER Provided those components are adapted one to the other
and are mutually complementary and that together they form a whole
which would not normally be offered for sale in separate parts.
Again, they form a whole which would not normally be offered for sale
in several parts.
BURTON, KRISTOPHER If you have two things you slapped together
and both are sold just as is.
BURTON, KRISTOPHER Separately, then it would not be a positive.
BURTON, KRISTOPHER Hey I'm not sure I can speak on about a fish tank
with accessories.
BURTON, KRISTOPHER Not sure about that example.
BURTON, KRISTOPHER And why each would need to be?
BURTON, KRISTOPHER Broke it out.
I mean, as far as house packaged.
But the fish tank, you know, if we're going by this, the fish tank can be sold
on its own and say a little plastic plants be sold on their own.
So maybe that's as was sold is that they're not in as good,
but could it be a good for retail sale?
Again that's what we need to to know.
BURTON, KRISTOPHER That's put up and retail sale mean three things.
So for you to have this 3B retail set, you need to have a consists
of at least two different articles with different classifications.
BURTON, KRISTOPHER So you have
to have different classifications 1/2 consist
of products for our products put together to meet a particular need
or carry a specific activity as I would sometimes say as a singular use
so they can all be used together to perform a specific activity
and then see are put up in a manner suitable for sale directly
to the end user without repackaging.
So they're in some form of box.
BURTON, KRISTOPHER Or other type of packaging
where they're all bundled together.
BURTON, KRISTOPHER For further breaking down
to this retail sale does not include sale products, which are intended
to be resold after further manufacturing preparation,
repacking or corporation with or into other goods.
BURTON, KRISTOPHER Then further their therefore only cover sets consisting
of goods which are tend to be sold to the end user,
where the individual goods are intended to be used together.
For example, different foodstuffs intend to be used together in the preparation
of ready to eat, meal or dish.
So.
BURTON, KRISTOPHER If you can take it straight off the boat container.
BURTON, KRISTOPHER And throw it on to the market shelf.
BURTON, KRISTOPHER That's what it means by what up for retail sale.
BURTON, KRISTOPHER Some examples.
BURTON, KRISTOPHER Set consists of the sandwich made with beef,
with or without cheese in a bun and packaged with potato chips.
And then you get a classification and heading 1616.
So for those that have not had lunch yet, there you go.
You can have a.
BURTON, KRISTOPHER Watch that.
BURTON, KRISTOPHER Then there's some other food examples.
BURTON, KRISTOPHER They're all does not.
How I recover selections or product, but up together,
because this enough for example.
BURTON, KRISTOPHER I guess they liked the food examples a can of shrimp can
of petite A can of cheese can slice bacon canned cocktail sausages.
BURTON, KRISTOPHER What it is?
What is it are we making?
BURTON, KRISTOPHER I don't know.
So in which case that's why that would not be a sad because it's not used
for singular purpose.
BURTON, KRISTOPHER Other than I guess just to eat,
but and here's some others.
I do handle a few of these.
BURTON, KRISTOPHER Umm you have hairdressing set with hair Clippers.
Come scissors, brush the towel and put up in a leather case.
BURTON, KRISTOPHER So we have it all bundled together.
BURTON, KRISTOPHER Hey, we here on slide 46.
BURTON, KRISTOPHER And further.
BURTON, KRISTOPHER By the gods, consistent
with separately packaged constituents popped together,
whether or not in common packaging and fixed proportions
for the industrial manufacturing, for example, where workers.
BURTON, KRISTOPHER Have not covered.
BURTON, KRISTOPHER What do I need to know?
What 3B deserve to be classified as they consisted of the material component
which gives them their central character,
and so far as the criteria is applicable as central character will vary
as between different kinds of goods.
It may for example, be determined by the nature of the material or component.
It's bulk, quantity, weight or value, or by the role of the constituent material
and the relationship to the use of the.
BURTON, KRISTOPHER OK, here's a little example.
BURTON, KRISTOPHER You have reath.
BURTON, KRISTOPHER And this is what I was talking about.
The visual interest you have.
All those follow colored leaves.
You have berries that will say are plastic foam
with the plastic lacquer over them.
Some little plastic pumpkins.
And I believe some natural pine cones is ahead since we're looking
to seven or two, we're no longer considering the plastic pine cones.
So when you look at this, what do you see?
BURTON, KRISTOPHER Me.
BURTON, KRISTOPHER You see the leaves.
BURTON, KRISTOPHER So typically those are made of polyester.
BURTON, KRISTOPHER Or what we'd say man made fibers.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER Even though it does have the other components
and say the berries or pumpkins may have a higher value,
a higher weight may have some other characteristics.
You see the leaves.
BURTON, KRISTOPHER And there we go.
BURTON, KRISTOPHER I'm not even touching festive articles.
BURTON, KRISTOPHER OK, what do I need to know about the goods made-up
of different parts shall be taking me not again repeating.
BURTON, KRISTOPHER All those which commands are attached to each other
to form practically in several whole, but also those with several components,
provided that these comments are adapted one
to the other are mutually complementary and are not normally offered
for sale in several parts.
BURTON, KRISTOPHER And as general, all the components
of these composite goods are put up in common packaging.
BURTON, KRISTOPHER And again, what do I need to know?
Because I put on retail sale, you need three things.
BURTON, KRISTOPHER That we're outside 51 consists of
at least two different articles which are classifiable different headings.
BURTON, KRISTOPHER They meet a particular need to
and then for Rule 3 is they're put together for sale without
for the repackaging and retail sale does not include sales of product,
which are intended to be resold after further manufacturing preparation,
repacking, or corporation with or into other goods.
BURTON, KRISTOPHER So next question we have,
I'm gonna just call us a barbecue set.
BURTON, KRISTOPHER We have tongs.
They basting brush, meat fork, spatula and carving knife.
BURTON, KRISTOPHER So is this a Jerry 3B set or Jerry 3C set?
BURTON, KRISTOPHER And we have requested one of these before
in the past.
Yeah, that would make it a little bit easier for you to know exactly.
BURTON, KRISTOPHER Umm.
But again we have to check.
BURTON, KRISTOPHER Heading, heading, language, then the subheading language.
BURTON, KRISTOPHER So.
So in this case, we have a GI one set.
BURTON, KRISTOPHER So even though you have.
BURTON, KRISTOPHER Multiple items put together for sale.
BURTON, KRISTOPHER It's provided right there as other sets
of assorted articles.
BURTON, KRISTOPHER Because you have.
BURTON, KRISTOPHER I think let me go back.
BURTON, KRISTOPHER You have the tongs.
BURTON, KRISTOPHER Which are in 215 the basing brush,
most likely 96 or three.
The fork 8/2/15 again the SPATULATED 215 and then the knife 8211
and then the packet the crates.
I'm going to guess somewhere in 42 too.
Don't hold me to that.
But you have the five items plus the.
BURTON, KRISTOPHER The container so.
BURTON, KRISTOPHER You go there.
BURTON, KRISTOPHER You got.
BURTON, KRISTOPHER Other or I guess table where the base metals.
So that's where you go in.
You got this other sets of sorted articles, there you go.
BURTON, KRISTOPHER Hey, how about this that you got a bunch of hair,
metal hair clips?
Got some with unicorns, smiley clouds and butterflies and rainbows.
It's very pretty, very colorful.
BURTON, KRISTOPHER Is this a JIRA?
BURTON, KRISTOPHER Right.
BURTON, KRISTOPHER 3B Set 3C set.
BURTON, KRISTOPHER I'll.
I'll move on so.
BURTON, KRISTOPHER We can't actually do Jerry 3
because they all have the same classification.
BURTON, KRISTOPHER They're all in 9615 at the heading level.
BURTON, KRISTOPHER So because they they're all.
BURTON, KRISTOPHER I'll just say hair slides is they're all hair slides
at 9/6/15, even if they're packaged together.
You have different ones.
BURTON, KRISTOPHER Umm, I guess the only way
they could be possibly different is say some of the decorations are.
BURTON, KRISTOPHER Plastic, summer metal or something else
that could possibly differentiate and have a different?
But then again, you'd have to go 6 to get to a 3B set,
but at the face these are all 9615 so you do not have a cent.
BURTON, KRISTOPHER There we go.
BURTON, KRISTOPHER Guy one, they all hold the same classification.
BURTON, KRISTOPHER Almost through your I3.
This one's a kind of a fun one.
When the goods cannot be classified by reference to three or three B,
they'll be classified and heading, which occurs last in the American order.
What do I need to know?
BURTON, KRISTOPHER Uh, when all seems lost and every component appears equal,
there is an answer.
Lassen tariff wins, so we would caution you to use this sparingly.
It's not like, uh.
I can't figure it out.
Let's just go 3C.
BURTON, KRISTOPHER Umm you should look at all the other factors
and try to get 3B.
BURTON, KRISTOPHER If possible.
BURTON, KRISTOPHER OK so.
BURTON, KRISTOPHER Is this a brush?
BURTON, KRISTOPHER Workout.
BURTON, KRISTOPHER It's uh for working on the eyebrows,
just in case you want is.
BURTON, KRISTOPHER Because yeah, you have brushes Combs of.
BURTON, KRISTOPHER Ah, OK yeah, brushes 9603 and Combs
of 9615 all put together in one product.
BURTON, KRISTOPHER So in this case, as the brush is 9603
and the comb is 9615.
BURTON, KRISTOPHER We do a GR3C, so this is an example.
BURTON, KRISTOPHER Umm it it it is a composite good.
It is not set.
It is composite good one item that are combined and then you have the two
and we would say that both merit equal consideration and to top it would go
as a column of plastic will say and then it would depend on the value or gross.
BURTON, KRISTOPHER And if you didn't attend my previous slide across is 144.
BURTON, KRISTOPHER 12 by 12.
BURTON, KRISTOPHER Hey, what about this honker?
It is the ultimate of multifunction knives.
BURTON, KRISTOPHER Say pliers, hex riches, nail Clippers, compass,
magnifying glass.
BURTON, KRISTOPHER I will reclassify this product.
BURTON, KRISTOPHER Lassen tariff.
BURTON, KRISTOPHER Yes, if MacGyver had one of these,
he wouldn't need all the other stuff.
BURTON, KRISTOPHER I don't know exactly how this would fit
in anyone's pocket, but.
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER I I think you guys are catching on.
BURTON, KRISTOPHER I think you guys are catching on.
BURTON, KRISTOPHER Trick yet again.
It's dry one.
BURTON, KRISTOPHER I'm holding knives are specifically provided for.
BURTON, KRISTOPHER And.
BURTON, KRISTOPHER This has a lot of folding knives head.
BURTON, KRISTOPHER So since it's provided for it by name.
BURTON, KRISTOPHER We have classified under heading to 11.
BURTON, KRISTOPHER There's the headquarters rolling on that
if you're interested.
BURTON, KRISTOPHER OK, almost almost get to the end.
BURTON, KRISTOPHER Umm.
BURTON, KRISTOPHER I don't know if something has already been provided
for like you just have to read the heading language.
Unfortunately, that's where knowledge or experience.
BURTON, KRISTOPHER Comes in.
I've just knowing what is in the Terra.
BURTON, KRISTOPHER It's it is very hard
to know sometimes cross can help you get an idea.
BURTON, KRISTOPHER How the customs online search but you just have
to kind of.
BURTON, KRISTOPHER No, the tariff and have a guess
of where something could be and read the heading language and know
if it's provided for in there.
BURTON, KRISTOPHER I would have to check.
I think there is.
BURTON, KRISTOPHER Folding there is a subheading for multitools
in that have knives.
I think there is one like the other say the like the Leatherman type
with the pliers.
But it's also possible that could go to a 2/5 for hand tools
and I would have to defer to the United handles that.
BURTON, KRISTOPHER OK, so for to me is kind of like a version
of three A where it's if you cannot be classified in accordance
with the above rules, it'll be a class under the heading appropriate.
The goods should most it can.
So what is it like?
BURTON, KRISTOPHER And it has many factors such as subscription,
character, purpose so.
BURTON, KRISTOPHER What do I need now?
BURTON, KRISTOPHER Umm.
Relates to a products that cannot be classified one through three
and it's necessary to compare the presenting good
with similar goods ordered term.
The goods which present goods are most they can and I struggled
to find an example.
We do not use your I4 much but I was able to find something.
BURTON, KRISTOPHER Hookah.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER Smoking pipes are the, you know, the stem, the bowl,
the little thing that you know, like Sherlock Holmes has.
BURTON, KRISTOPHER It says under heading 9614, smoking pipes
and cutting pipes and bowls and cigar cigarette holders and parser up.
It does not say who goes.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER We do classify.
BURTON, KRISTOPHER Because 196 fourteen.
But they wanna put a little ashes there.
BURTON, KRISTOPHER Lucas can sometimes fall
under restricted merchandise,
in which case those determinations are made by headquarters.
BURTON, KRISTOPHER I'm knives.
Also, we have switchblades that sometimes can be.
BURTON, KRISTOPHER Uh, so if we receive something that appears
to be whether it is or not, whether it's has a potential
of being restricted merchandisable for it to CBP headquarters,
the restricted merchandise branch and they will make a final determination
on whether it's restrict or not.
They decide it's restricted, it cannot be entered in the US legally.
I do know that even though we'll say there are the states loud,
marijuana is still against the federal law, so.
BURTON, KRISTOPHER Even though you mean oh, it's fine for, you know,
Colorado.
It's not fun to import in the US.
So just as a heads up on that.
BURTON, KRISTOPHER But there is example of four.
BURTON, KRISTOPHER DRI 5 is.
BURTON, KRISTOPHER Uh, mainly for packaging, so you have some that comes
along with it and then you don't have to classify it separately.
BURTON, KRISTOPHER Logs as specific so like
in this case it says camera cases, musical instruments, gun cases,
drawing instruments.
BURTON, KRISTOPHER Umm, the note is that the article must come in with it.
BURTON, KRISTOPHER And it must not provide these central characters,
so the container itself must not provide the central character.
BURTON, KRISTOPHER And then 5A is or the basic packaging.
BURTON, KRISTOPHER With that's signaling you something.
BURTON, KRISTOPHER So 5A specifically shaped or fitted to a specific article.
BURTON, KRISTOPHER You know the violin case you have,
it's basically fitted for the violin, the violin in it.
You import the case and the violin is classified as the violin.
BURTON, KRISTOPHER And as under ability to protect what's inside.
BURTON, KRISTOPHER And shall be taken to cover only those articles
which are presented with the article which they are intended, you know,
or I think it's mentioned.
Binocular case you had the benign binoculars in there.
There's something normally sold with them and it does give this character.
BURTON, KRISTOPHER Hear some additional examples.
Yeah, there's a binocular cases.
Examples not covered are silver caddies containing tea.
Silver is much more expensive than the the content container or
or ornamental ceramic bowl containing sweets.
BURTON, KRISTOPHER You know if if the container is 50 bucks
and the inside is 5 bucks because the container and 5/8 doesn't apply.
BURTON, KRISTOPHER This rule 5B is, you know, I guess now it's like the.
BURTON, KRISTOPHER Paperboard and plastic cover.
I've got this pack material that are normally unused for,
but switch they relate to.
BURTON, KRISTOPHER A carrying bag for a case.
BURTON, KRISTOPHER Umm.
BURTON, KRISTOPHER Hey, I would say in general that
that may bear a little bit more into a heading towards 42 or two,
which I can't speak to too well, but I'm going to say.
BURTON, KRISTOPHER If the case is what's important,
then I guess it's possible, but as the rule states,
you have the principal product with its case
and so you something you put on outside of it no longer.
BURTON, KRISTOPHER Would be that and also is that house normally sold.
BURTON, KRISTOPHER I don't know if you typically sell a case
with a carrying bag.
BURTON, KRISTOPHER It's possible, but I'm going to say probably it carry back
for a case wouldn't qualify under 5A, it would be classified separately.
BURTON, KRISTOPHER So what do I need to now 5A containers?
It must be presented with the article which they are intended
whether or not the articles are packed separately for Community transport.
The container does not give the whole essential character packaging discovered
the classification pack.
Material and pack detainers OK normally used.
BURTON, KRISTOPHER Which they relate.
So in this case you have toothbrushes 9603 and little caps.
BURTON, KRISTOPHER As I sure where those will go,
but we'll just just count those because you're buying it from the toothbrushes
and it has the little paperboard backing and the plastic over cover.
BURTON, KRISTOPHER Is going to be 596 or three two brushes.
BURTON, KRISTOPHER I think just one or two more questions
and then we'll be wrapping up.
We did go just touch over, so I apologize for that, but we are homeless,
done, how do we classify this knife with the sheath?
BURTON, KRISTOPHER We got a I'll just say it wouldn't handle,
wouldn't brass handle?
But we'll say primarily would.
BURTON, KRISTOPHER Base metal cutting blade and hay leather sheath.
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER You would all be correct and the great thing about this.
BURTON, KRISTOPHER Example is again the tariff provides
for sheath type knives.
So in the chapter notes it does state.
BURTON, KRISTOPHER Term sheet nice refers to a fixed blade knife contained
in a substantial holster.
I.e. A sheath of a kind juice in hunting and fishing.
BURTON, KRISTOPHER And then if you looked at here.
BURTON, KRISTOPHER You have.
BURTON, KRISTOPHER Two.
Well, see, I again.
That's where you have to look at.
BURTON, KRISTOPHER The subheading language?
Yes, she type noise here and she type knives here.
So which one is it?
BURTON, KRISTOPHER No.
BURTON, KRISTOPHER So following or ruler,
we have other knives having fixed blades.
BURTON, KRISTOPHER So yes, uh, she's nice.
Do not fold.
Some do, but I'd say most of them are fixed then
with rubber or plastic handles or other.
So in this case this has wouldn't handle.
So we go to.
BURTON, KRISTOPHER And it's not a hunting knife, but says she's knife.
So drop down and.
BURTON, KRISTOPHER End up down here for a sheet type knife
with a it'll other than rubber or plastic.
BURTON, KRISTOPHER That makes sense.
BURTON, KRISTOPHER Dry 6.
BURTON, KRISTOPHER If you know that your eyes we only have 6,
so that means we are on the last one.
This one is one that I mentioned at the beginning
because essentially says that once you get here, you start all over again.
BURTON, KRISTOPHER You just take your ruler, move over a tick.
BURTON, KRISTOPHER The role one through five are governed test
this tandis classification, so heading level with the same heading
and then as it mentions one Dash 2 dash.
BURTON, KRISTOPHER Umm, because they explanatory notes are done
at international level.
Most international classifications are.
BURTON, KRISTOPHER I'm only out to the six digit in the US,
we got to 10, so.
BURTON, KRISTOPHER But you have to ask the set 8 to 8, six to six.
You can't compare Essex digit tariff number to a 10 digit tariff number.
BURTON, KRISTOPHER What do I need now?
BURTON, KRISTOPHER Umm.
And for those wanting a little, let lesson.
BURTON, KRISTOPHER And that is pandas.
When the necessary changes haven't been made classification
and seven heading levels with these same heading.
BURTON, KRISTOPHER And when the wood Dash subheading is
that is more specific has been chosen, and when the subheading itself
subdivided then and only then sell the text for the two dash 7 headings
be taken to consideration.
So as I said, you have to take it at the four digit before you can take it
to the six digit before you take the digit.
So what about martial arts knives and or weapons?
BURTON, KRISTOPHER Those could possibly go into hiding or chapter 93,
which I do not handle.
Some knives I do.
BURTON, KRISTOPHER If it's a knife is a knife.
BURTON, KRISTOPHER It could go to 8211,
but in some cases based on its need,
or it could even be possibly sporting equipment in Chapter 95.
That would be one of those to send in and with all the information
and we can look at further.
BURTON, KRISTOPHER So let's apply what we have learned.
We have have a.
BURTON, KRISTOPHER Hair slide.
The headband of heading 9615.
BURTON, KRISTOPHER And we'll say it's covered with black plastic pearls,
imitation gemstones.
BURTON, KRISTOPHER A little flowers, interiors, some type of fabric,
and just for fun, we'll say the core is metal, so we have a composite good of.
BURTON, KRISTOPHER Some plastics, some fabric and metal.
BURTON, KRISTOPHER So how would we classify this?
BURTON, KRISTOPHER Well, we know it's a hair slide.
So we go into 9615.
BURTON, KRISTOPHER Right here.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER Air slots.
Then we have Combs, hair slides and the like.
BURTON, KRISTOPHER And then of hard rubber or plastic and other.
BURTON, KRISTOPHER So in this case.
BURTON, KRISTOPHER As the same with the visual appeal.
BURTON, KRISTOPHER Can you buy this with the user buys this
when you look at it, you're like, why would somebody buy?
Are they buying it for the the fabric interior?
That'll be a goods ahead.
No ones gonna really see that.
BURTON, KRISTOPHER Are they buying it for the strong metal core?
BURTON, KRISTOPHER Not really.
I mean that does help, but we'll say.
BURTON, KRISTOPHER It's for the pearls and the.
BURTON, KRISTOPHER Commentation gemstones
just for the sake of this exercise.
So there the pearls and the gemstones are plastic, so we go to counts
of hard rubber or plastics.
You're going to say that this composite good by Jiri 3B is an article
of plastic.
So Nice 16.
BURTON, KRISTOPHER Volunteer sides of hard rubber plastics.
Is it a come?
As I said, yes or no.
It is not a comb.
So you drop down the other.
BURTON, KRISTOPHER And then not set with imitation pearls
or imitation gemstones.
Well, we do have the we'll just say gemstones and pearls right there.
So you drop down again to other.
So in this case, you end up with 96, fifteen 11555 thousand.
BURTON, KRISTOPHER And I said I just pulled this image off the Internet
that may or may not be what this is.
So this is just kind of a representative example of how we classify something.
I can't say it's exactly this headband is classified there, but from best guess
that's where we go.
BURTON, KRISTOPHER So.
BURTON, KRISTOPHER Bingo.
Bingo.
Beer.
To the end of the presentation.
Again, sorry, I wouldn't touch over.
BURTON, KRISTOPHER If you guys have any questions, I'm I'm.
BURTON, KRISTOPHER Free to answer those now.
BURTON, KRISTOPHER Or if you want to sign off and enjoy the rest
of your afternoon, feel free to do that as well.
BURTON, KRISTOPHER As is now typically I do not do that much with.
Well, of course we all use GRI, but I was just gonna say that that you know,
my my specialty is more of the classification of my merchandise, so.
BURTON, KRISTOPHER You know, in the future will probably sit more
to my classification stuff so.
BURTON, KRISTOPHER This is just a a free fund.
For your information, we do not offer certificates for continuing education,
sorry.
BURTON, KRISTOPHER A copy of the presentation.
It will be recorded and posted online.
I think that was noted earlier to repeat.gov
under trade and I believe it's.
BURTON, KRISTOPHER That the.
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER OK, perfect.
BURTON, KRISTOPHER Sure.
BURTON, KRISTOPHER I have the question comes in or you can type
in your question.
BURTON, KRISTOPHER There's, uh, there's a little.
BURTON, KRISTOPHER Umm, like yes.
Stakeholder engagement?
That's what I was trying to remember.
Sauder, trade stakeholder engagement.
Uh, so sorry.
Go ahead.
BURTON, KRISTOPHER Yes, I can hear you.
BURTON, KRISTOPHER So it depends on what those items are.
BURTON, KRISTOPHER I'm one.
I mean, if you have multiple components.
BURTON, KRISTOPHER You would have to meet as per those three things,
it has to have the singular use package for retail to be asset.
BURTON, KRISTOPHER Umm.
Otherwise you classify them individually, then you'd have
to look at the essential character.
So we'll just make it easy and say you have two items is 1 item valued
higher than the other?
Does it hold a higher weight?
A higher utility to the overall set?
If that's case, you could actually classify it by the one earlier
in the tariff by the one that provides the central character.
But say you have the two components,
they are equal in all standing, you know,
OK, they might be off by like $0.50.
BURTON, KRISTOPHER But both are valued like 100 bucks once 100
and $0.50.
BURTON, KRISTOPHER The others you know, not $99.50.
We call it more or less equal, in which case then, yeah.
Then you would go last and tariff, but typically you were going
to either classify them individually or you're going to find the one
that has essential character to classify something.
Lassen tariff is kind of the fail safe that if you can't, can't come up
with any reason to classify, then you go with less interior.
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER Any other questions?
BURTON, KRISTOPHER I see another hand raised.
BURTON, KRISTOPHER OK.
BURTON, KRISTOPHER I'll give it another few minutes.
I see it's about 248.
If anyone has any questions, I'll just hang on till about 2:50.
BURTON, KRISTOPHER And then I'll call it at 2:50.
Go ahead and close this one down.
So if you have any last last minute questions, feel free to pass those.
And also my e-mail is right there.
So if you need to e-mail me, you can do that as well.
BURTON, KRISTOPHER Everyone attend.
Thank you very much for joining and you're welcome.
I hope you found it informational.
BURTON, KRISTOPHER Yes, but thank you all for for joining.
OK, one, maybe another question I see raised hand.
BURTON, KRISTOPHER OK, well with that.
BURTON, KRISTOPHER Going once, going twice.
BURTON, KRISTOPHER We'll go ahead and close out the meeting,
so thank you all very much.
Again, have a wonderful afternoon and until next year for Max Webinar.
I take care.