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March 17, 1999

CLA-2-90:RR:NC:MM:114 D88491

CATEGORY: CLASSIFICATION

TARIFF NO.: 9006.53.0070

Mr. Arthur Becker
Bnox Inc.
575 Madison Avenue
Tenth Floor
New York, New York 10022

RE: The tariff classification of a Bnox camera preloaded with film

Dear Mr. Becker:

In your letter dated March 4, 1999, you requested a tariff classification ruling. A sample of a Bnox camera preloaded with film was submitted with your letter for review.

The submitted item number 99021536 is a fixed-focus 35 mm reloadable camera from China. The camera is preloaded with ASA 400 film. The camera is capable of taking regular and telephoto pictures by moving a switch above the viewfinder. The submitted camera has two distinct fixed focal points and two distinct lenses. One lens is for the wide angle pictures and one lens is for telephoto pictures. The camera is without a built-in flash unit.

The camera will be imported and sold to customers with the film preloaded. You have stated that the country of origin of the film is not known for certain at this time, but it is expected to be Italy, China or the United States.

After using the film, the consumer will remove the back of the camera and remove the film. There is a key attached to the sample camera that can be used to reload film. To reload, a new roll of film is put into the camera and the key is used to wind the film into the camera.

The applicable subheading for the Bnox camera with preloaded film will be 9006.53.0070, Harmonized Tariff Schedule of the United States (HTS), which provides for photographic (other than cinematographic) cameras; other cameras; other, for roll film of a width of 35 mm; other; other. 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 Barbara Kiefer at 212-637-7058.

Sincerely,

Robert B. Swierupski
Director,

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