The tariff classification of a LED Cat Key Ring, a LED Skull Key Ring, and a LED Pumpkin Key Ring from China.

N105658 May 19, 2010 CLA-2-95 OT:RR:NC:N4:425 CATEGORY: Classification TARIFF NO.: 9505.90.6000 Ms. Valerie Cason Customhouse Broker 33 Thomas Street Coram, New York 11727 RE: The tariff classification of a LED Cat Key Ring, a LED Skull Key Ring, and a LED Pumpkin Key Ring from China. Dear Ms. Cason: In your letter dated May 10, 2010, on behalf of Kikkerland Design Inc. of New York, New York, you requested a tariff classification ruling for three “novelty key rings” sold for Halloween. The first style, item #KRL21TC, LED Cat Key Ring, consists of a three-dimensional, full-bodied plastic black cat that measures approximately 2” in height x ¾” in width x 2” in length, and is attached to a ¾” chain with a spring wire gate snap hook. Housed inside the cat figure are batteries, LED lights and a sound module. When a button on the top of the cat’s head is pressed, the cat emits a piercing “meow-like” wail and its eyes glow an eerie bright blue. The second style, item #KRL18B, LED Skull Key Ring, consists of a three-dimensional, full-bodied plastic skull, with sunken black eye sockets, that measures approximately 1-1/2” in height x 1” in diameter, and is attached to a ¾” chain with a spring wire gate snap hook. Housed inside the skull are batteries, LED lights and a sound module. When a button on the top of the skull is pressed, the skull emits a frightening laugh and its eyes glow an eerie bright red. The third style, item #KRL05T, LED Pumpkin Key Ring, consists of a three-dimensional, full-bodied plastic jack-o’-lantern that measures approximately 1-1/4” in diameter, and is attached to a ¾” chain with a spring wire gate snap hook. Housed inside the jack-o’-lantern are batteries, LED lights and a sound module. When a button on the bottom of the jack-o’-lantern is pressed, the jack-o’-lantern emits a frightening laugh and its eyes, nose and mouth glow an eerie bright yellow. Although these articles are referred to in your ruling request as “key rings”, they are not considered key rings for Customs’ purposes as they do no have a split wire ring, nor are they utilitarian articles designed to organize, carry and store keys. Instead, these articles are intended as hanging decorations for Halloween. The applicable subheading for item #KRL21TC, LED Cat Key Ring, item #KRL18B, LED Skull Key Ring, and item #KRL05T, Pumpkin LED Key Ring, will be 9505.90.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Other: Other." The rate of duty will be Free. 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 Wayne Kessler at (646) 733-3026. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division