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NY 880033

November 12, 1992

CLA-2-74:S:N:N1:115 880033


TARIFF NO.: 7419.99.5050

Mr. Robert Keller
Expeditors Int'l of Washington, Inc.
578 Eccles Ave.
South San Francisco, CA 94080

RE: The tariff classification of musical keychains from Japan.

Dear Mr. Keller:

In your letter dated November 2, 1992, you requested a tariff classification ruling.

The subject items are musical keychains. They are listed as item numbers 69-0248, 69-0180, 77-3879 and 77-3887. Each of these four items is made of a 3-piece construction consisting of the following:

1) A steel wire ring
2) Copper connecters
3) Copper photo lockets - which when opened plays music

The subject item numbers 69-0248, 69-0180, 77-3879 and 77-3887 are composite articles that prima facie appear to be classifiable under more than one heading, each equally specific. Classification will accordingly be determined on the basis of that portion of the article which imparts the essential character. We have concluded that there is no essential character for all four composite articles.

Therefore, it shall be classified under the heading which occurs last in numerical order among those which equally merit consideration. In all four instances, the copper photo lockets' classification is last.

The applicable subheading for all four of the musical keychains, item numbers 69-0248, 69-0180, 77-3879 and 77-3887, will be 7419.99.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of copper: other: other. The duty rate will be 5% ad valorem.

Consideration was given to classifying the musical keychains, item numbers 69-0248, 69-0180, 77-3879 and 77-3887, under subheading 7326.90.9090, HTS, as you have suggested. However, as all of these items are considered composite articles, and the copper photo lockets' classification appears last, the other copper articles provision is more appropriate.

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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