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NY G84790

December 5, 2000

CLA-2-90:RR:NC:MM:105 G84790


TARIFF NO.: 9019.10.2020

Mr. Arlen T. Epstein
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of a Four-in-One Multi-Handyman from China

Dear Mr. Epstein:

In your letter, dated November 20, 2000, on behalf of Avon Products, Inc., you requested a tariff classification ruling.

The sample consists of an electrical power module which uses four AA batteries and which serves as the handle in use. It has an on-off switch. It is about 4 inches long and 1.5 inches in diameter, except at the connecting end, which is approximately a 2.3 inch square. There are four heads that can be attached, each specially shaped to dock securely into the handle module - a vacuum cleaner, a flashlight, a 5-blade fan, and a mini-ball massager. The vacuum cleaner and fan each has its own rotary motor, and the massager has its own vibrating motor.

The vacuum cleaner head will be connected to the handle when imported, but it is very easy to remove it and attach any of the other heads. We note that, when used as a vacuum cleaner, the suction produced is extremely weak and that the Four-in-One Multi-Handyman in the largest print, by far, on the packaging does not emphasize any one use.

We agree that the import is a composite good and that an electric vacuum cleaner, per se, would be classified in HTS 8509, a flashlight in 8513, a fan in 8414, and a massager in 9019. Noting HTS General Rule of Interpretation 3-c, the last heading which equally merits consideration is HTS 9019.

We therefore agree that the applicable subheading for this item will be 9019.10.2020, Harmonized Tariff Schedule of the United States (HTS), which provides for handheld, battery operated, massage apparatus. The general rate of duty will be free and remains unchanged in 2001.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

The sample is being returned to you in a separate mailing.

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 Sheridan at 212-637-7037.


Robert B. Swierupski
National Commodity

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