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NY A83438

June 5, 1996

CLA-2-95:RR:NC:FC: 225 A83438


TARIFF NO.: 9502.10.0020; 9503.90.0030

Ms. Annette McCormack
Meijer, Inc.
2929 Walker Avenue, N.W.
Grand Rapids, Michigan 49544-9428

RE: The tariff classification of a doll and toy with attached key chains from China

Dear Ms. McCormack:

In your letter dated May 6, 1996, received in this office on May 8, 1996, you requested a tariff classification ruling.

Two sample key chains were submitted with your inquiry. The "Barbie" key chain is composed of an actual "Barbie" doll figure which stands approximately 10 cm in height. The doll has articulated arms, legs and head. A metal key chain with key ring is permanently attached to her back. The figure is molded of plastic and her clothing, makeup and hair have been painted on. The item comes in an assortment which includes a variety of doll fashions. It will be imported packaged in a window box with a cardboard hanger for display purposes.

The "Etch-A-Sketch" key chain consists of a miniature sized working "Etch-A-Sketch" and attached metal key chain with a metal key ring. The turning of two knobs creates a picture, in outline form, on the screen. In order to erase the picture and begin again one must shake the article to clear the screen. The product will be imported packaged on a blister card for retail sale. In a phone conversation you granted this office permission to retain the samples for training purposes.

The above described key chains are considered composite goods, which are goods that consist of different materials or are made up of different components. Classification is based upon the General Rules of Interpretation. GRI 3(b) states in
part that "composite goods made up of different components which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character". This office finds the essential character of the subject articles to be imparted by the "Barbie" doll and "Etch-A-Sketch" toy.

The applicable subheading for the "Barbie Key Chain" will be 9502.10.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for dolls representing only human beings: whether or not dressed: other: not over 33 cm in height. The rate of duty will be free.

The applicable subheading for the "Etch-A-Sketch Key Chain" will be 9503.90.0030, Harmonized Tariff Schedule of the United States (HTS), which provides for other toys (except models), not having a spring mechanism. The rate of duty will be free.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Alice J. Wong at 212-466-5538.


Roger J. Silvestri

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