The tariff classification of an auto clipboard from China

NY B87533 July 31, 1997 CLA-2-87:RR:NC:MM:101 B87533 CATEGORY: Classification TARIFF NO.: 8708.29.5060 Ms. Lori Aldinger Rite Aid Corporation P.O. Box 3165 Harrisburg, PA 17105 RE: The tariff classification of an auto clipboard from China Dear Ms. Aldinger: In your letter dated June 13, 1997, you requested a tariff classification ruling. The item (shown at the top of Page 2) is a formed piece of black, hard plastic measuring 8«"L X 3 4/5" W. It's main shape is rectangular with an upside-down T-shaped head portion. The various components of the item are - 1. Attached into the post portion of the upside-down T- shaped head portion is a silver, metal spring; this spring is attached on it's opposite end to an upside-down T-shaped clip; 2. Held between the crossbar portion of the upside-down T- shaped clip and the rectangular main body of the item is a 4«"L X 3«"W notepad of white paper; 3. Two L-brackets extend from the right side of the rectangular main body which hold a 5¬"L X 17/40"W, non- refillable ink pen; 4. The pen is attached to the back of the rectangular main body by a spring-shaped, black, soft plastic cord; 5. Attached through the post portion of the upside-down T- shaped head portion of the main body are dual, levered, black, hard plastic swivel brackets (one on each side) with a rod through the end of the "T"'s post; 6. Molded at the end of the swivel brackets is a circular piece of black, hard plastic; 7. Inserted into the circular piece of black, hard plastic is a black, soft rubber suction cup measuring 8 " in circumference. You state that the function of this item is to attach, via the suction cup, to the interior of a vehicle and allow convenient note-taking and map-holding for the occupants of the vehicle. You further state that the item will be purchased FOB Hong Kong for a unit cost of .91› each and that it will be imported into the U.S. through various east and west coast ports. The retail box which contained the item you included with your Ruling Request states that the item is manufactured by ETON COMPANY of New Orleans, Louisiana with an ETON COMPANY Item Number of 3741. The applicable subheading for the Auto Clipboard (Rite Aid Item #972209) will be 8708.29.5060, Harmonized Tariff Schedule of the United States (HTS), which provides for Parts and accessories of . . . motor vehicles . . . : Other parts and accessories of bodies: Other: Other: Other. The rate of duty will be 2.7% ad valorem. 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 Robert DeSoucey at 212-466-5667. Sincerely, Robert B. Swierupski Chief, Metals & Machinery Branch National Commodity Specialist Division