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NY I82531

May 29, 2002

CLA-2-85:RR:NC:1:108 I82531


TARIFF NO.: 8513.10.2000, 8520.90.0080

Ms. Lorianne Aldinger
Rite Aid Corporation
P.O. Box 3165
Harrisburg, PA 17105

RE: The tariff classification of combination flashlight/mini tool set device/key ring, a voice recorder and a sports timer from China.

Dear Ms. Aldinger:

In your letter dated May 9, 2002 you requested a tariff classification ruling.

The items in question are a combined flashlight/ mini tool set/key ring device, a voice recorder and a sports timer.

All of the articles are pocket sized designed for personal use. The flashlight/mini tool set/key ring is designed to be carried on one’s person and offers multiple use capability. It can be used for the specific defined functions as a flashlight for illumination, as a repair kit for personal objects such as eyewear or simply as a key ring. It is the opinion of this office that the item is a composite good based upon its multi-functional capacity. Note 3 to Section XVI of the Harmonized Tariff Schedule of the United States (HTS) provides, in pertinent part, that unless the context requires otherwise, machines adapted for the purpose of performing two or more complimentary functions or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function

Based upon a review of the article, it is the opinion of this office that the combination flashlight/mini tool set, key chain does not have a single principal function. Therefore classification will be in accordance with GRI 3c.

The voice recorder is a hand held device, which is designed to be carried on one’s person. It allows the user to record voice messages for future reference. Based upon a practical demonstration it actually records an audio message, onto a chip, which can be later retrieved by the user.

The applicable subheading for the combination flashlight/mini tool set/ key chain will be 8513.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for Portable electric lamps designed to function by their own source of energy Lamps: Flashlights. The duty rate will be 12.5 percent ad valorem.

The applicable subheading for the voice recorder will be 8520.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for Magnetic tape recorders and other sound recording apparatus, whether or not incorporating a sound reproducing device: Other Other. The duty rate will be free

Your inquiry does not provide enough information for us to give a classification ruling on sports timer. Your request for a classification ruling should include the operating instructions, which explain the functions of the device as well as a sample. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 Michael Contino at 646-733-3014.


Robert B. Swierupski

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