&&Based on the information received, the product is a retaining clips, which attach to a metal ring (100% iron) to a shovel. The ring attaches the blade of the shovel to the handle.

&&Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Interpretative Rules (GIRs) for the Harmonized System (HS). Section 11 of the Customs Tariff states that in interpreting the headings and subheadings, regard shall be had to the World Customs Organization's (WCO) Explanatory Notes to the Harmonized Commodity Description and Coding System.&&&&General Interpretative Rule 1 (GIR 1) directs that titles of Sections, Chapters and sub-Chapters are provided for ease of reference only. For legal purposes, classification shall be determined according to the terms of the heading and any relative Section and Chapter Notes. Similarly, General Interpretative Rule 6 (GIR 6) directs that classification shall be determined according to the terms of those subheadings and any related Subheading Notes.&&&&A proposed tariff classification number was not provided in your submission; the tariff classification number as determined is found under the section titled “Decision”.&&&&The metal ring was deemed part of a shovel of Chapter 82. Legal Note 2 to Chapter 82 indicates that “Parts of base metal of the articles of this Chapter are to be classified with the articles of which they are parts, except parts separately specified as such and tool-holders for hand tools (heading 84.66). However, parts of general use as defined in Note 2 to Section XV are in all cases excluded from this Chapter”. This product meets the definition of “parts of general use” defined in Note 2 to Section XV, more specifically as “Tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel of heading 73.07.&&