&&The Valent O-220-1/1200-14+4 is a composite good that consists of two parts: a bent, galvanized steel wire holder with a diameter of 3 mm x 220 mm long which holds two reserves of a polypropylene twine wound around the steel holder. The first reserve has 14 meters of twine, and the 2nd reserve has 4 meters of twine. The twine density is 8.333 dtex (0.833 g/m).&&&&The holder and twine form a ‘system’ that connects tomatoes (and other climbing plants) to overhead trellising wires in a greenhouse, keeping the plants upright during their growing season. The steel holder attaches to the overhead wire and the twine drops to reach the bottom to guide the plants. As the plant grows, the holder releases additional string as required.&&&&The holder is created from galvanized steel wire using a wire-bending machine. The twine is manufactured from polypropylene granules mixed with UV stabilizers through an extrusion process. The extruded tape is then twisted into polypropylene twine and wound onto the holder.&&&&This product is imported in bulk with 308 units per carton. Based on importer information, the Polypropylene twine weighs approximately 152 grams and represents $0.12 of the total $0.17 cost. The galvanized steel holder weighs approximately 24 grams and represents $0.04 of the total cost.

&&Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Rules for the Interpretation of the Harmonized System and the Canadian Rules set out in the schedule. 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) Compendium of Classification Opinions and Explanatory Notes to the Harmonized Commodity Description and Coding System (HS).&&&&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 headings and any relative Section or 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.&&&&In your application for an advance ruling, Tariff Item 5607.49.90 by application of GIR 3(b) was suggested, asserting that the twine provides the essential character of the composite good based on function, cost and weight. This Tariff Item 5607.49.90 is incorrect.&&&&The twine component meets the technical terms of Heading 56.07 which covers “Twine, cordage, ropes and cables, whether or not plaited or braided and whether or not impregnated, coated, covered or sheathed with rubber or plastics”.&&&&The holder component is included by heading 73.26 as “other articles of steel”. General Explanatory Note (1) to heading 73.26 specifically names “trainers for trees, sweet peas, etc.”. This product acts as a trainer for climbing plants such as tomatoes.&&&&Composite goods are classified by the material or component that gives them their "essential character," according to General Interpretative Rule 3(b).&&&&The product is a tomato trellising tool made of two distinct parts that are equally important. The twine may have a higher weight and cost of the two components but it would not work on its own without the steel holder attached to the trellising. The holder provides the vertical support for the weight of a mature tomato plant. The holder’s shape is designed to release the twine. In addition, the steel holder has a long lifespan, while the twine is biodegradable and may only be good for one growing cycle. Since both the twine and holder are equally important to the function of the device, General Interpretive Rule 3(c) applies which is the last numerical order.