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March 16, 1999

CLA-2-44:RR:NC:SP:230 D88660


TARIFF NO.: 4414.00.0000; 3214.10.0020; 4420.10.0000

Mr. Dennis Healy
RKD Premium Products Inc.
14630 S.E. Market Ct.
Portland, OR 97233

RE: The tariff classification of impression-making/display kits from China.

Dear Mr. Healy:

In your letter dated February 24, 1999, you requested a tariff classification ruling. Two sample kits, both identified as “D.J. Bear’s Little Impression,” were submitted and will be retained for reference.

The first sample consists of two items put up together for retail sale in a printed paperboard box: a picture frame and a sealed foil packet containing several ounces of a doughy substance called “clayment.” The picture frame actually consists of two 5 1/2" x 7 1/2" wooden frames (each with a fiberboard back) held together by metal hinges. The “clayment” is said to be a mixture of powdered limestone, petroleum jelly and ethylene acetate.

The “clayment” is intended to be used by the purchaser to create an impression (casting) of a child’s handprint or footprint. When exposed to the air, the impression will harden into an “unbreakable stone-like material” in 5 to 10 days. It can then be saved for posterity and displayed in one side of the double frame. The other side of the frame can be used to display the child’s picture and vital statistics.

The second sample is a similar kit, except that instead of a picture frame it includes a 7 3/4" x 11 1/2" wooden plaque suitable for hanging on a wall. The “clayment” is again intended to be made into a stone-like casting, which in this instance can eventually be displayed on the plaque.

Since it appears that the individual components comprising each of these kits will serve two different needs or activities (i.e., the making of an impression and the holding/display of same), for tariff purposes they will be classified as separate items rather than together as “sets.”

The applicable subheading for the picture frame will be 4414.00.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for wooden frames for paintings, photographs, mirrors or similar objects. The rate of duty will be 3.9%.

The applicable subheading for the “clayment” (in both versions of the kit) will be 3214.10.0020, HTS, which provides, in pertinent part, for resin cements and other mastics. The rate of duty will be 3.7%.

The applicable subheading for the wooden plaque will be 4420.10.0000, HTS, which provides for statuettes and other ornaments, of wood. The rate of duty will be 3.2%.

Please note that when imported into the United States, the kits will be required to be marked with their country of origin (e.g., “Made in China”), legibly, in a conspicuous place, and in a manner sufficiently permanent to reach the ultimate purchaser.

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 Paul Garretto at 212-637-7009.


Robert B. Swierupski

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