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HQ 956702

October 5, 1994

CLA-2 CO:R:C:F 956702 GGD


TARIFF NO.: 3407.00.20; 3924.90.55; 4409.10.65; 4821.10.20 9503.90.70

Ms. Cecilia A. Cormier
Hasbro, Inc.
1027 Newport Avenue
Post Office Box 1059
Pawtucket, Rhode Island 02862-1059

RE: "Play-Doh Fun Sounds Playshop;" Modeling Paste Set

Dear Ms. Cormier:

This letter is in response to your inquiry of May 23, 1994, concerning the classification under the Harmonized Tariff Schedule of the United States (HTSUS), of an article's individual components, and the article itself, identified as a "Play-Doh Fun Sounds Playshop," to be imported from China. We understand that the components may be imported separately or together. A sample was submitted with your inquiry.


The sample article, identified by product no. 23480, is comprised of several components - 2 six ounce containers of "play-doh" brand modeling compound; a "fun sounds" structure with 3 presser handles; a "fun sounds" sound unit with battery box; 2 plastic die strips; 6 plastic molding cups; a label sheet; a wooden rolling pin; and a plastic trimmer knife. A child may manipulate the play-doh, molds, tools, and sound structure to make various shapes and amusing sounds.


1) Whether the "Play-Doh Fun Sounds Playshop" is properly classified in heading 9503, HTSUS, as other toys; or in heading 3407, HTSUS, as modeling pastes put up for children's amusement.

2) What is the proper classification of each of the individual components?


Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). The systematic detail of the harmonized system is such that virtually all goods are classified by application of GRI 1, that is, according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs may then be applied. The Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System, which represent the official interpretation of the tariff at the international level, facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and GRIs.

The article consists of various components that are classifiable individually in the following headings: the plastic trimmer knife in heading 3924, the label sheet in heading 4821, the "fun sounds" structure, sound unit, and battery box, and the plastic die strips and molding cups in heading 9503 (all as parts of toys), the rolling pin in heading 4409, and the play-doh in heading 3407. When considering whether any one heading would accommodate all the components, we look to heading 3407.

Heading 3407, HTSUS, provides for "Modeling pastes, including those put up for children's amusement; preparations known as "dental wax" or as "dental impression compounds", put up in sets, in packings for retail sale...; other preparations for use in dentistry with a basis of plaster...." The ENs to heading 3407 define modeling pastes as plastic preparations generally used by artists or goldsmiths for making models and by children for amusement purposes. The ENs further state that the heading covers "[a]ssorted modelling pastes, including those put up in sets for the amusement of children...." It is apparent that each item of the set is put up with the modeling paste to enhance the set's amusement value for children. As heading 3407 is sufficiently broad to cover all the components, it specifically describes the "Play-Doh Fun Sounds Playshop." The proper subheading for the set is 3407.00.20, HTSUS.


The "Play-Doh Fun Sounds Playshop," identified by item no. 23480, is classified in subheading 3407.00.20, HTSUS, the provision for "Modeling pastes, including those put up for children's amusement." The applicable duty rate is 10 percent ad valorem.

The individual components comprising the "Play-Doh Fun Sounds Playshop" (item no. 23480), if imported separately, are classifiable under the specific subheadings provided below:

The plastic trimmer knife is classified in subheading 3924.90.55, HTSUS, the provision for, among other items, "...other household articles...of plastics: Other: Other." The applicable duty rate is 3.4 percent ad valorem.

The label sheet is classified in subheading 4821.10.20, HTSUS, the provision for "Paper and paperboard labels of all kinds, whether or not printed: Printed: Printed in whole or in part by a lithographic process." The applicable duty rate is 8.8 cents per kilogram.

The "fun sounds" structure, handles, sound unit, and battery box, and the plastic die strips and molding cups are classified in subheading 9503.90.70, HTSUS, the provision for "Other toys...and accessories thereof: Other: Other: Other." The applicable duty rate is 6.8 percent ad valorem.

The wooden rolling pin is classified in subheading 4409.10.65, HTSUS, the provision for "Wood...continuously shaped...along any of its edges or faces, whether or not planed, sanded or finger-jointed: Coniferous: Wood dowel rods: Sanded, grooved, or otherwise advanced in condition." The applicable duty rate is 7.6 percent ad valorem.

The "play-doh" brand modeling compound is classified in subheading 3407.00.20, HTSUS, the provision for "Modeling pastes, including those put up for children's amusement." The applicable duty rate is 10 percent ad valorem.


John Durant, Director

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