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NY 886340

May 21, 1993

CLA-2-84:S:N:N1:110 886340


TARIFF NO.: 8470.10.0040

Siegel, Mandell & Davidson
One Astor Plaza
1515 Broadway, 43rd Floor
New York, N.Y. 10036

RE: The tariff classification of a "Clipboard Calculator" from China and/or Taiwan.

Dear Mr. Eisen:

In your letter dated May 17, 1993, on behalf of Avon Products, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a "Clipboard Calculator". This article is a rectangular shaped plastic clipboard incorporating a solar powered calculator. The clipboard which measures approximately 13 1/2-inches in length by 9 1/4- inches in width, is constructed of rigid plastic, and is calibrated on one side in inches, and on the other side in centimeters. The multi-functional calculator component is incorporated into the center top section of the plastic clipboard, and actually serves as the "clip". The solar powered calculator which measures approximately 5 1/2-in length, by 2 1/4-inches in width, features a 24-key keyboard, and an LED display. The calculator also possesses four solar panels for absorbing light.

The essential character of this composite article is the calculator. GRI 3(b) is noted. An examination of the physical construction and features of the merchandise reveals that the essential character of the article is imparted by the calculator component, which serves as the focal point of the product, and the "clip" portion of the clipboard.

The applicable subheading for the "Clipboard Calculator" will be 8470.10.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for display only electronic calculators capable of operation without an external source of power. The rate of duty will be 3.7 percent ad valorem.

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
Area Director

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