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NY N021746

January 29, 2008



TARIFF NO.: 8531.80.0050

Jay Reynolds
Customs Broker
JP Reynolds Company Inc.
1850 Eller Drive, Suite 401
Fort Lauderdale, FL 33316

RE: The tariff classification of “Ab Memory” from China

Dear Mr. Reynolds:

In your letter dated January 9, 2008 on behalf of IED Global Incorporated, you requested a tariff classification ruling.

The item concerned is referred to as the “Ab Memory”. The item is comprised of either a metal or plastic rectangular housing measuring approximately 3.5 inches in length by 2.5 inches in width by .75 inches in-depth. There is a metal clip attached to the back of this device which is used to affix the item to an individual’s belt. The back of the housing incorporates a pressure sensitive switch that activates an audible, as well as visual (LED light) alarm. The item is controlled by an on/off switch and is powered by a lithium battery.

The purpose of the “Ab Memory” is to help an individual improve their posture. Once attached to an individual’s belt, the unit will alert the wearer to the fact that they are slouching. Slouching causes pressure on the switch which activates the audible and visual alarm. The alarm acts as a reminder to tighten one’s abdominal muscles and to straighten one’s back.

The applicable subheading for the “Ab Memory” will be 8531.80.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus: Other apparatus: Other”. The rate of duty will be 1.3%.

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 Steve Pollichino at 646-733-3008.


Robert B. Swierupski

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