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NY N010358

May 24, 2007



TARIFF NO.: 4903.00.0000

Jeffrey Carlson
Penguin Group(USA) Inc.
405 Murray Hill Parkway
East Rutherford, NJ 07073

RE: The tariff classification of a draw-with-chalk book from China

Dear Mr. Carlson:

In your letter dated April 24, 2007 you requested a tariff classification ruling.

A sample was submitted of “Little Cloud - A Draw-with-Chalk Book” for our examination and will be returned to you as requested. The paperboard book which measures approximately 8½” x 11” captures the imagination of youngsters throughout the ten page text with comparisons of fun shapes to a cloud in the sky. The book has an extended back cover with an attached blister pack that contains a plastic storage tray holding three pieces of white chalk and a small white rubber sponge eraser. There are alternating pages that are specially treated for chalk writing. These illustrated pages allow drawing space for the child’s interactive participation of creating their own pictures. The drawing chalk and eraser are intended to enhance the child’s reading experience.

For tariff classification purposes, this product will be regarded as “goods put up in sets for retail sale” whose essential character is imparted by the book.

The applicable subheading for the “Little Cloud Draw-with-Chalk Book” will be 4903.00.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for children’s pictures, drawing or coloring books. The rate of duty will be free.

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 Paul Garretto at 646-733- 3035.


Robert B. Swierupski

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