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NY B87176

July 28, 1997

CLA-2-95:RR:NC:SP:225 B87176


TARIFF NO.: 9503.90.0030; 9102.91.2000; 8513.10.2000

Ms. Mona Webster
Target Stores
33 South Sixth Street
P.O. Box 1392
Minneapolis, Minnesota 55440-1392

RE: The tariff classification of assorted key chains from China

Dear Ms. Webster:

In your letter dated June 26, 1997, received in this office on June 30, 1997, you requested a tariff classification ruling.

The four items submitted are all marketed as key chains. The first article, "C-3PO Flashlight Keychain" (style 88-025), consists of a small flashlight, approximately 3 1/2 inches in length, attached to a metallic key ring. The flashlight comes installed with one "AAA" size battery. Also included, on the blister card package is a replacement light bulb for the unit.

The second item, a "Lightsaber Keychain" (style 88-023), is composed of an imitation saber sword attached to a metallic key ring. The saber glows and produces crashing sounds when a button on the side is pressed. The saber has a retractable rounded blade and measures 5 1/2 inches upon full extension. It operates on three cell batteries which are included. The item is packaged on a blister card.

The next product is called "R2-D2 Keychain Clock" (style 88-021). This article consists of a 2 inch plastic robot/clock attached to a metallic key ring. The robot figure incorporates a small digital clock in the chest area. The clock, in addition to the time, features a day and date option with an alarm. Two buttons underneath the display screen are used to adjust all settings. The article is packaged on a blister card for retail sale.

The final item, "Star Destroyer Keychain" (style 88-022), combines a metallic key ring attached to a plastic space ship. The space ship measures about 3 inches in length and comes installed with two cell batteries that activate lights and sounds. One button operates only the red taillights and the other causes both taillights and sound effects to function. The item is packaged on a blister card.

All of the key chains are considered composite goods, which are goods consisting of different materials or 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". Based upon the foregoing, the described keychains are classified as follows:

The applicable subheading for the "Lightsaber Keychain" (style 88-023), and "Star Destroyer Keychain" (style 88-022) 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.

The applicable HTS subheading for the LCD clock/key ring, "R2-D2 Keychain Clock" style number 88-021, will be 9102.91.2000, which provides for other watches...battery-powered: with opto-electronic display only. The duty rate will be 3.9 percent on the watch movement and case, plus 5.3 percent on the battery.

The applicable subheading for the "C-3PO Flashlight Keychain" (style 88-025), will be 8513.10.2000, HTS, which provides for portable electric lamps designed to function by their own source of energy...; flashlights. The rate of duty will be 17.5 percent ad valorem.

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.


Gwenn Klein Kirschner
Chief, Special Products Branch

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