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NY 814558

January 2, 1997

CLA-2-84:S:N:N1:110 814558


TARIFF NO.: 8471.92.2000

Ms. Maureen D. Pearson
Katten Muchin & Zavis
525 West Monroe Street, Suite 1600
Chicago, Illinois 60661-3693

RE: The tariff classification of a keyboard from China.

Dear Ms. Pearson:

In your letter dated September 7, 1995, on behalf of Vtech Industries, Inc., you requested a tariff classification ruling. The merchandise under consideration involves a "Sound Learning Talking Keyboard" which is an alpha-numeric keyboard which plugs into a personal computer and is designed especially for children. The keyboard is packaged for retail sale with one software title, contained on six 3 1/4 inch floppy disks. A cable is included to permit the user to plug the keyboard into the printer port of the user's personal computer. The keyboard contains a special toggle key on the back of the item to permit the keyboard and printer to be plugged into the same printer port on the computer. The keyboard measures approximately 11 inches by 15.5 inches. This keyboard is nonfunctional unless it is plugged into a personal computer.

The "Sound Learning Talking Keyboard" is specially designed for use by children. Large, chunky keys consisting of letters in alphabetical order, a number pad, a musical keyboard, and colorful shape buttons comprise a major portion of the item. Additionally, there is an extra large track ball and enter button to accommodate a child's developing motor skills.

This "Sound Learning Talking Keyboard" keyboard can be considered to be a "unit" of an ADP system as defined in Legal Note 5(B) to Chapter 84 of the HTS since it is connectable to the central processing unit either directly or through one or more units. As previously noted, the keyboard is nonfunctional unless it is plugged into a personal computer.

The applicable subheading for the "Sound Learning Talking Keyboard" will be 8471.92.2000, Harmonized Tariff Schedule of the of the United States (HTS), which provides for other input or output units, whether or not entered with the rest of a system and whether or not containing storage units in the same housing. The rate of duty will be free .

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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