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June 10, 1999

CLA-2-45:RR:NC:2:230 E82356


TARIFF NO.: 4504.90.0000

Mr. Arlen T. Epstein
Tompkins & Davidson, LLP
One Astor Place
1515 Broadway
New York, NY 10036-8901

RE: The tariff classification of a cork bulletin board with push pins from China

Dear Mr. Epstein:

In your letter dated May 14, 1999, on behalf of your client Avon Products Inc., you requested a tariff classification ruling.

The ruling was requested on Avon’s Product Profile number PP 193157, a “Figural Cork Board with Push Pins.” A sample was submitted which will be returned to you as you requested.

The sample is a small bulletin board with a picture of a hedgehog printed on the front. It is roughly oval shaped and measures approximately 12-1/2 inches long by 9-1/4 inches wide by 1/4 inch thick. It is made of cork particles agglomerated with a polyurethane binder. The board is packaged together with four push pins inserted in a strip of cork and wrapped with blister pack for safety. The cork board and the pins are packed together in a clear plastic bag with various information printed on it such as the country of origin, Avon’s name and address, the plastic bag warning and the name of the product “Hedgehog Noticeboard” with “Drawing pins included.”

The cork bulletin board and the push pins will be imported and sold together in a retail package. They are clearly intended to be used together for the purpose of posting notes and the like. They meet the description of “goods put up in sets for retail sale.”

The classification of such goods is governed by General Rule of Interpretation (GRI) 3(b) of the Harmonized Tariff Schedules. GRI 3(b) states that goods put up in sets for retail sale shall be classified together according to the component which gives them their essential character. The essential character of this set is imparted by the cork bulletin board. The applicable subheading for the “Figural Cork Board with Push Pins”, Avon’s PP 193157, will be 4504.90.0000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for other articles of agglomerated cork. 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 Paul Garretto at 212-637-7009.


Robert B. Swierupski

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