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March 19, 1999

CLA-2-85:RR:NC:1:110 D89215


TARIFF NO.: 8520.90.0080

Mr. James C. Alberdi
A.J. Arango, Inc.
1516 E. 8th Avenue
Tampa, Florida 33605

RE: The tariff classification of a Mouse pad with Memory from Hong Kong.

Dear Mr. Alberdi:

In your letter dated March 5, 1999, on behalf of Questech International, you requested a tariff classification ruling.

The merchandise under consideration involves a combination article that consists essentially of a memo recording device, calculator, mouse pad and digital clock. The mouse pad, clock, calculator and recorder are mounted on a plastic housing that is approximately 9 1/2 inches in length and 9 1/2 inches in width. The recorder device is detachable , and the small digital clock has a tilt screen display.

The recorder device has 80 second recording, and includes batteries. The mouse pad is approximately 6" x 9" and is constructed of neoprene. The digital clock is solar powered. The calculator incorporates a tilting 8 digit display for easy reading, has a dual powered solar/battery, and 20 function keys.

This mouse pad with memory consists of different materials and is made up of different components. It thus meets the definition of a composite good noting GRI-3 (b). The significant components of this composite good are exemplified by the calculator (8470), recorder (8520), and mouse pad (8473). Since no clear “essential character” is evident for this composite good, it shall be classified under the heading which occurs last in numerical order among those which equally merit consideration, as per GRI-3 (c).

The applicable subheading for the Memo Mouse with Memory will be 8520.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for other sound recording apparatus. 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 Art Brodbeck at 212-637-7019, or Michael Contino at 212-637-7039.


Robert B. Swierupski

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