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NY F87995

June 15, 2000

CLA-2-73:RR:NC:N1:113 F87995


TARIFF NO.: 7326.20.0050

Ms. Cindy Hazlett
Warner Bros.
4000 Warner Boulevard
Burbank, CA 91522

RE: The tariff classification of a keyring from China

Dear Ms. Hazlett:

In your letter dated June 2, 2000, you requested a tariff classification ruling.

The sample you provided is a Power Puff Waterball Keyring. The item consists of a split ring connected to a water ball decoration by a chain. Customs has consistently held that, when a key chain has both a functional and non- functional component it is the functional component, which provides the article’s essential character. See Headquarters Ruling Letter (HRL) 950636, dated January 16, 1992. Further, in HRL 960118 dated July 28, 1997, we determined that a functional key chain/ring, not a voice synthesizer comprised a key ring’s essential character. See also, HRL 959473 dated April 8, 1997 and HRL 958452 dated July 3, 1996.

Concerning the subject articles, it is the ring/chain component, which makes up the utilitarian portion of the article.

The applicable subheading for the keyring will be 7326.20.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, articles of iron or steel wire. The rate of duty will be 3.9 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 James Smyth at 212-637-7008.


Robert B. Swierupski

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