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NY 817894





January 11, 1996

CLA-2-84:RR:NC:MA:110 817894

CATEGORY: CLASSIFICATION

TARIFF NO.: 8470.10.0060

Ms. Maureen D. Pearson
Katten Muchin & Zavis
525 West Monroe Street, Suite 1600
Chicago, Illinois 60661-3693

RE: The tariff classification of a calculator device from China.

Dear Ms. Pearson:

In your letter dated December 1, 1995, on behalf of VTech Industries, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a hand held electronic calculator device which is known as "Smart Pad". This device, which measures approximately 6 « inches by 4 inches, stores data which can be received via the function keys. "Smart Pad" contains learning activities which can teach vocabulary, word association, geometry, and number placement, as well as amusement activities such as word puzzles, work search, anagrams, and trivia. The function keys also permit the device to be used as a calculator, calendar, schedule keeper, and telephone and address book. Although the user can input data into the article, "Smart Pad" cannot be freely programmed by the user. It is designed and marketed for use by children ages nine and older.

We would consider this article to be a composite machine, since it incorporates both calculating, data recording, and information retrieval functions. The essential character, noting GRI-3(b), is exemplified by the data recording, reproducing, and display functions.

The applicable subheading for the "Smart Pad" calculator device will be 8470.10.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for pocket-size data recording, reproducing, and displaying machines with calculating functions. The rate of duty will be 2.9 percent ad valorem.

This ruling is being issued under the provisions of Section 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 Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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