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NY C84261




February 13, 1998

CLA-2-85:RR:NC:1:108 C84261

CATEGORY: CLASSIFICATION

TARIFF NO.: 8520.90.0080

Ms. Joanne Balice
CBI Distributing Corp.
2400 W. Central Rd.
Hoffman Estates, IL 60195-1930

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

Dear Ms. Balice:

In your letter dated february 4, 1998, you requested a tariff classification ruling.

The sample you submitted (Walkie Recorder) is a recording device on a key ring. The recording device is approximately 3 inches in height, 1 3/4 inches in width and 1/2 inch thick. The item has an on/off switch, record button and a play button. There is also a speaker, approximately 1 inch in diameter, and an indication light which lights up when you record and play back. The device operates by pushing the record button and speaking near the recorder. The speaker has 3 seconds to record before the device starts playing back. To play back the message, the play button is pushed. The device cannot retain more than one message. The device has a tab on it which is pierced and the key ring is attached to the device by way of a ring and chain that passes through the pierced section of the item.

The applicable subheading for the Walkie Recorder will be 8520.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for "[m]agnetic tape recorders and other sound recording apparatus, whether or not incorporating a sound reproducing device: [o]ther: [o]ther." The rate of duty will be 0.8 percent ad valorem. 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 Harvey Kuperstein at 212-466-5672.

Sincerely,

Robert B. Swierupski
Director

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