The tariff classification of novelty key rings from China

N057577 May 4, 2009 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.20.0070 Mr. Azhar Ayub Twinklers Limited 122 Granville Road London NW2 2LD United Kingdom RE: The tariff classification of novelty key rings from China Dear Mr. Ayub: In your letter dated March 27, 2009 and received in our office on April 15, 2009, on behalf of KB Toys, you requested a tariff classification ruling. Two samples of the item were submitted for our review. The merchandise is identified as Pinky Pens (item number P-94). Each Pinky Pen is composed of a steel split wire key ring attached by a steel swivel connector to a 1-inch ball point pen. The pen is stored inside a plastic housing and projects outward by sliding a button. Both pen key rings feature a photo of actress and musician Hannah Montana on the plastic housing. The packaging options include a 36-piece or 60-piece display stand and a 12-piece clip strip. The display unit will be pre-assembled and wrapped in poly film in an inner carton and an outer cardboard box. The applicable subheading for the Pinky Pens will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem. Your inquiry does not provide enough information for us to give a classification ruling on the display stand and clip strip. What is the composition of each of these items? Please provide any advertising, marketing, promotional materials and any pictures of the display stand and clip strip. If you decide to resubmit your request, please include all the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section. 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