The tariff classification of 5 “LEGO” key rings from China

N297364 June 14, 2018 CLA-2-95:OT:RR:NC:N4:424 CATEGORY: Classification TARIFF NO.: 9503.00.0073 Ms. Eileen Family GEODIS Trade Consultants The Navy Yard 5101 S. Broad Street Philadelphia, PA 19112-1404 RE: The tariff classification of 5 “LEGO” key rings from China Dear Ms. Family: In your letter received May 16, 2018, you requested a tariff classification ruling on behalf of LEGO Systems, Inc. Five samples of “LEGO” key rings were submitted with your inquiry. The articles include Disney’s Belle, item number 853782, Butterfly Girl, item number 853795, Marvel’s Black Panther, item number 853771, Corn Cob Guy, item number 853794 and DC’s Cyborg, item number 853772. All of the objects are plastic LEGO mini-doll figurines, measuring approximately 1.5” in length, attached to a steel metal split key ring. The mini figurines contain moveable arms and legs and are not detachable from the metal rings. The LEGO key rings will be considered as composite goods for Customs purposes. The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. General Rule of Interpretation (GRI) 3(b), Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes, classification of composite goods are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. This office finds that the LEGO mini figurines confer the essential character of the composite good. The LEGO key rings are principally designed for the amusement of children 6 years of age and older. The applicable subheading for the 5 LEGO key rings will be 9503.00.0073, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tricycles, scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: 3 to 12 years of age.” 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 https://hts.usitc.gov/current. 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 Roseanne Murphy at roseanne.j.murphy@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division