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NY 872110

March 20, 1992

CLA-2-38:S:N:N1-F:238 872110


TARIFF NO.: 3822.00.5090

Ms. Paula Nachman
Nachman Enterprises, Inc.
P.O. Box 17886
Richmond, VA 23226

RE: The tariff classification of "Sun Check" skin sensitivity monitors from Germany.

Dear Ms. Nachman:

In your letter dated January 23, 1992, resubmitted on March 9, 1992, you requested a tariff classification ruling.

The three submitted samples, in the form of a "credit card", a "wrist watch" and a "sticker", respectively, are skin sensitivity devices which monitor an individual's exposure to the harmful rays of the sun. The card and the watch types have separate areas (four on the card and three on the watch) that correspond to different skin types (e.g., "normal", "super sensitive", etc.). The sticker type has only one area. An unexposed strip of film (photographic) that changes color with different levels and durations of exposure to the sun is located under each area. When a strip is exposed to the sun (under the same condition as the sun-bather), it colors gradually. When the exposed strip matches the reference color surrounding it, it is time for the wearer to come in from the sun. You state in your letter that none of the three samples contain methyl chloroform (1,1,1-trichloromethane) or carbon tetrachloride.

The applicable subheading for these three products will be 3822.00.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for composite diagnostic or laboratory reagents, other than those of heading 3002 or 3006: other: other. The rate of duty will be 5 percent ad valorem.

This merchandise may be subject to the regulations of the Food and Drug Administration. You may contact them at 5600 Fishers Lane, Rockville, Maryland 20857, telephone number (202) 443-3380.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire

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