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NY N004056

December 21, 2006



TARIFF NO.: 7326.20.0070

Mr. Azhar Ayub
Twinklers Limited
122 Granville Road
London NW2 2LD
United Kingdom

RE: The tariff classification of key rings from China.

Dear Mr. Ayub:

In your letter dated November 13, 2006, on behalf of KB Toys, you requested a tariff classification ruling.

The sample provided with your letter is identified as the FunKey Flasher, item number M-63W. It consists of a steel split wire ring attached by a metal double C ring to a flat plastic Winnie the Pooh character. The character measures approximately 2 inches in length. A light emitting diode (LED) is located inside the plastic Winnie the Pooh character. It flashes by pressing the middle of the character. You indicated in your letter that the FunKey Flashers are available in different colors, shapes and characters. A LED will be located inside each of the plastic characters. The packaging options include a 36-piece or 60-piece display stand, a 12-piece clip strip or a 144-piece sidekick display. The display unit will be pre-assembled and wrapped in poly film in an inner carton and an outer cardboard box.

The applicable subheading for the FunKey Flashers will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the display stand, clip strip and sidekick display. What is the composition of each of these items? Please provide any advertising, marketing, promotional materials and any pictures of the display stand, clip strip and sidekick display. If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 646-733-3018.


Robert B. Swierupski

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