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NY 817979




January 26, 1996

CLA-2-85:RR:NC:MA: 112 817979

CATEGORY: CLASSIFICATION

TARIFF NO.: 8541.40.2000; 8513.10.2000; 7117.19.9000

Mr. Mike Chun
Delta Express
765 Route 83, Suite 122
Hartford Center
Bensenville, IL 60106

RE: The tariff classification of various electrical products from China

Dear Mr. Chun:

In your letter dated December 22, 1995, on behalf of Buztronics, Inc., you requested a tariff classification ruling.

The submitted samples cover five (5) distinctive products. The "light circuit module" consists of a battery operated circuit board, one (1) inch in diameter. Two (2) sets of electrical leads are affixed to the board and each set is connected to a tiny light emitting diode (LED). A pin clasp is also soldered to the board, since the board is intended for incorporation into a promotional button. When the protective plastic sleeve is removed from the pin and it makes contact with the clasp, the LED's will begin flashing.

The "electronic blinking button" consists of the "light circuit module", including the pin clasp, assembled within a metal bottlecap. The bottlecap is decorated with advertisement for either Lite ICE beer or Molson ICE beer. These bottlecaps will be imported in both a retail package and in bulk, unpackaged form.

The "point of purchase light harness" consists of a printed circuit board with a variable speed switch and a mounted plastic battery holder, and five (5) sets of electrical leads which are soldered to the board. An LED is soldered to the other end of each set of leads. This harness is used in promotional displays where flashing lights are used.

The "keychain flashlight" is a metal keychain with a circular plastic attachment which emits a light when squeezed. The "sound button" consists of a circular plastic housing, containing electronic components, and a metal facing with a promotional display for Budweiser beer. A pin clasp is also affixed to the housing. When a button switch on the housing is pressed, the "sound button" emits a noise resembling that of a croaking frog.

The applicable subheading for the "light circuit module" and the "point of purchase light harness" will be 8541.40.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for light emitting diodes. The rate of duty will be 1.2 percent ad valorem. The applicable subheading for the "electronic blinking button" and "sound button" will be 7117.19.9000, HTS, which provides for other imitation jewelry of base metal. The rate of duty will be 11 percent ad valorem.

The applicable subheading for the "keychain flashlight" will be 8513.10.2000, HTS, which provides for portable electric lamps designed to function by their own source of energy...; flashlights. The rate of duty will be 20 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 David Curran at 212-466-5680.

Sincerely,

Roger J. Silvestri

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