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NY C82197




December 4, 1997

CLA-2-84:RR:NC:1:110 C82197

CATEGORY: CLASSIFICATION

TARIFF NO.: 8470.10.0060

Ms. Joanne Balice
CBI Distributing Corp.
2400 West Central Road
Hoffman Estates, Illinois 60195-1930

RE: The tariff classification of a key ring calculator from China.

Dear Ms. Balice:

In your letter dated December 3, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves a key ring calculator that is approximately 2 3/8 inches in length by 1 1/4 inches in width, and has a depth of 1/8 of an inch. The calculator unit incorporates a clear plastic flip-up keyboard cover, a 20 key keyboard, an eight digit display unit, and is battery operated. Attached to the calculator is a metal chain which is approximately 1 inch in length. A key ring is affixed at the end of this chain.

This key ring calculator would meet the definition of a composite good, since it incorporates both calculating and key holding functions. The "essential character" of this device, noting GRI-3(b), is exemplified by its calculating functions.

The applicable subheading for the key ring calculator will be 8470.10.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for other electronic calculators capable of operation without an external source of power. The rate of duty will be free.

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 Art Brodbeck at 212-466-5490.

Sincerely,

Robert B. Swierupski
Director,

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