The tariff classification of educational dressing frames from China

N149195 March 4, 2011 CLA-2-63:OT:RR:NC:N3:351 CATEGORY: Classification TARIFF NO.: 6307.90.9889 Ms. Diane Romero Lakeshore Learning Materials 2695 East Dominguez Street Carson, CA 90895 RE: The tariff classification of educational dressing frames from China Dear Ms. Romero: In your letter dated February 7, 2011, you requested a tariff classification ruling. You submitted a sample of three educational devices you call Buckle, Lace & Tie Dressing Frames. The dressing frames are made of woven textile fabric over a padded medium density fiberboard. The dressing frames measure 9-1/2” x 11-1/2”. The three frames are intended to teach young children to dress themselves. One board has parallel metal grommets, so a child can practice cross-threading and tying shoe laces. Another has three buckles, so a child can learn to open and close buckle straps. The last has three sets of laces to teach a child to tie bows. The applicable subheading for the Buckle, Lace & Tie Dressing Frames will be 6307.90.9889, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for other made up textile articles, other. The rate of duty will be 7% ad valorem. You suggest the dressing frames may be classified as a toy in 9503, HTSUS, which provides for “Tricycles, scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof…Other: Labeled for use by persons 3 to 12 years of age.” However, the dressing boards, although designed for young children, are not toys principally designed for amusement. The dressing boards are, as you have advertised, used to practice dressing skills and to develop a child’s dexterity. 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 the World Wide Web at http://www.usitc.gov/tata/hts/. The samples will be returned as you requested. 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 Mitchel Bayer at (646) 733-3102. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division