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March 29, 1999

CLA-2-84:RR:NC:1:110 D89850

CATEGORY: CLASSIFICATION

TARIFF NO.: 8470.10.0060

Ms. Joanne Balice
CBI Distributing Corp.
2400 W. Central Rd.
Hoffman Estates, IL 60195-1930

RE: The tariff classification of a Calculator/Clock/Key ring from China

Dear Ms. Balice:

In your letter dated March 15, 1999, you requested a tariff classification ruling.

The sample submitted with your ruling request indicates that this combination article consists essentially of a small calculator that incorporates a display unit and keyboard, and is attached to a metal key chain. The calculator/clock portion is approximately 2 ¾ inches in length and about 1 ½ inches in width. It also incorporates a plastic flip-up keyboard cover, a 20 key keyboard, a display unit, and batteries. Attached to the calculator/clock is a short metal chain which holds the metal key ring.

This style model # 54979 calculator/clock key ring would meet the definition of a composite good, since it incorporates both calculating, clock, and key ring functions. The “essential character” of this device, noting GRI-3 (b), is exemplified by its calculating functions.

The applicable subheading for the calculator/clock/key ring will be 8470.10.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for other electronic calculators capable of operation without an external source of power. 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.

Sincerely,

Robert B. Swierupski
Director,

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