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NY B89792




October 14, 1997

CLA-2-91:RR:NC:MM:114 B89792

CATEGORY: CLASSIFICATION

TARIFF NO.: 9106.90.85

Mr. Edward L. Hart, Jr.
V. Alexander & Co., Inc.
P.O. Box 30250
Memphis, Tenn. 38130-0250

RE: The tariff classification of a Key Organizer from China

Dear Mr. Hart:

In your letter dated September 16, 1997, on behalf of The Sharper Image Corporation, you requested a tariff classification ruling.

The key organizer is item SI550. The SI550 features five removable key rings, 360 degree swivel action key ring attachments, spring loaded key guard, easy sliding key track, a light emitting diode (LED) guide light to illuminate maps, keyholes, etc., a key finder device that is activated by clapping, and a parking timer. A sample of SI550 was not provided; a sample of a similar model, the SI658, was furnished for our review. The parking timer is a count down timer which counts in 15 minute increments. It emits an audible alert, which makes it useful, for example, in keeping track of the time you are parked at a parking meter.

The applicable subheading for the SI550 key organizer will be 9106.90.85, Harmonized Tariff Schedule of the United States (HTS), which provides for other time of day recording apparatus and apparatus for measuring, recording or otherwise indicating intervals of time. The rate of duty will be 27 cents each plus 4.2 percent plus 1.5 cents per jewel.

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 Barbara Kiefer at 212-466-5685.

Sincerely,

Robert B. Swierupski
Director,

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