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NY 813550

September 7, 1995

CLA-2-84:S:N:N3:102 813550


TARIFF NO.: 7318.14.1000; 8414.59.6090; 8414.90.1080; 8424.89.9080; 8501.10.4060

Mr. James F. Welton
2300 East Higgins Road, Suite 200-7
Elk Grove Village, IL 60007

RE: The tariff classification of the "Squeeze Breeze" combination spray mister and fan, and parts thereof, from unspecified countries.

Dear Mr. Welton:

In your letter dated July 31, 1995, on behalf of your client, Innovative Design Enterprises, Inc., you requested a tariff classification ruling.

The article at issue is known as the "Squeeze Breeze". It is a combination of a polypropylene spray bottle and a battery-operated plastic fan. The unit is designed to provide a cooling stream of air, coupled with an occasional vapor mist. In your letter you indicated four possible import scenarios. The first is that the product would be completely assembled ,packaged and imported from one country. The second version is that, with the exception of the spray bottle, the unassembled parts would all be imported from one producing country. It is assumed that they would be imported in bulk, not in individual, knock-down sets. The third configuration would be to import only the assembled fan from one country. The final scenario was that all of the parts that make up the completed "Squeeze Breeze" would be imported individually, and from various countries.

The parts of the Squeeze Breeze, as we have determined, consist of the following: a polypropylene spray bottle; two ABS plastic housings for the fan assembly; two steel #4-16 x 3/4", type AB cross-recessed, pan head, tapping screws; a DC electric motor under 18.65 watts; an ABS plastic fan blade cap; and three Ethylene Vinyl Acetate Foam fan blades. In that you are unable to provide us with the countries of origin of the above parts, we can only provide you with the Harmonized Tariff Schedule numbers, not the applicable rates of duty. Since we assume that all of the parts will be imported packed separately from each other, the tariff items will not differ based on whether they are imported from one or more countries. It is also our position that the essential character of the completed Squeeze Breeze is imparted by the fan.

The applicable subheading for the completely assembled Squeeze Breeze, as well as for just the assembled fan attachment, will be 8414.59.6090, Harmonized Tariff Schedule of the United States (HTS), which provides for other fans, other, axial. The polypropylene spray bottle is classifiable under HTS item 8424.89.9080 which covers other mechanical appliances for projecting, dispersing or spraying liquids or powders, other. The electric motor is classified under the provision covering electric motors, of an output under 18.65 w, other, DC, other, HTS item 8501.10.4060. The two steel screws are provided for under 7318.14.10000, HTS, which covers self tapping screws having shanks or threads with a diameter of less than 6 mm. The balance of the parts are classifiable under HTS item 8414.90.1080, which provides for parts of fans, other

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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