The tariff classification of a novelty key ring from China

N035935 September 2, 2008 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.20.0070 Ms. Dana Antoine Carmichael International Service 533 Glendale Boulevard Los Angeles, CA 90026-5097 RE: The tariff classification of a novelty key ring from China Dear Ms. Antoine: In your letter dated August 13, 2008, on behalf of Bandai America, you requested a tariff classification ruling. A sample of the item was submitted for our review and will be returned to you. The sample you submitted is identified as the Mugen Pop Pop. It consists of a steel split wire ring connected by a short chain to a novelty attachment. The novelty item is a small plastic box containing an electronic chip. The outside of the box has eight buttons. When the buttons are pressed, the box emits a sound similar to bubble wrap being popped. Other special sounds are also programmed, such as a barking dog and a door chime. After one hundred “pops”, the Mugen Pop Pop will emit one of these special sounds. In your letter, you suggest classification of the Mugen Pop Pop as a toy of heading 9503 or as a game of heading 9504. However the article does not provide sufficient amusement value to be classified as a toy or game. The applicable subheading for the Mugen Pop Pop will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem. 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 Ann Taub at 646-733-3018. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division