The tariff classification of key chains from China.

NY C82644 January 5, 1998 CLA-2-73:RR:NC:GI:115 C82644 CATEGORY: Classification TARIFF NO.: 7326.20.0050; 8513.10.2000 Ms. Jennifer F. Kessinger Katten Muchin & Zavis 525 West Monroe Street Suite 1600 Chicago, Illinois 60661-3693 RE: The tariff classification of key chains from China. Dear Mr. Kessinger: In your letter dated December 11, 1997, you requested a tariff classification ruling on behalf of your client, M-B Sales of Melmont, IL. The subject items are described as follows: 1) Show 'N Grow - which is an egg-shaped plastic item with an attached steel key ring. When the upper and lower halves of the egg are pulled apart, a character on a color label is revealed. 2) Flash-A-Gotchi - which is an egg-shaped plastic item with an attached steel key ring. The front of the item features a screen area with a translucent label and a row of three buttons beneath the translucent label. When the screen is depressed, a light is emitted by a red LED light from a hole at the bottom of the egg. The light is powered by a non-replaceable battery. 3) Color Changer - which is an egg-shaped plastic item attached to a steel key ring. On the front of the egg is a therma-chromatic color label. Whet the heat is applied to the label on the front of the egg (e.g., by rubbing the label), the therma-chromatic label changes to depict a character. 4) Removable Transformer/Doggie - which is an item composed of a plastic, removable item enclosed within an egg-shaped hinged plastic item attached to a steel key ring. The egg features a label on the outside and opens on hinges. Inside the egg is a plastic dog-shaped figure. The dog's legs may be pulled down manually. A button on the front of the dog opens and closes the dog's mouth. Your items are considered composite goods, consisting of different materials or made up of different components. Theses items shall be classified as if they consisted of the material(s) or component(s) which gives them their essential character. In the instances for the Show 'N Grow, Color Changer and the Removable Transformer/Doggie, the steel key ring(s) imparts the essential character. For the Flash-A-Gotchi, the light portion imparts the essential character. The applicable subheading for the Show 'N Grow, Color Changer, and the Removable Transformer/Doggie will be 7326.20.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel wire, other. The duty rate will be 4.3% ad valorem. The applicable subheading for the Flash-A-Gotchi will be 8513.10.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for flashlights. The duty rate will be 15% ad valorem. Consideration was given to classifying all of these products under subheading 9503.90.0030, HTS, as you have suggested. However, these items are not considered to be toys. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this 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 Melvyn Birnbaum at 212-466-5487. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division