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March 1, 1999

CLA-2-48,49:RR:NC:2:234 D88625

CATEGORY: CLASSIFICATION

TARIFF NO.: 4817.20.4000, 4911.91.2040

Mr. D. A. Pearson
Managing Director
Courtier Fine Arts Limited
3 Drakes Courtyard
291 Kilburn High Road
London NW6 7JR, England

RE: The tariff classification of correspondence cards, from England

Dear Mr. Pearson:

In your letter dated February 18, 1999, you requested a tariff classification ruling for certain paper cards which you denominate "Correspondence Cards". Samples were submitted, which will be retained for reference.

Five (5) samples were furnished, each consisting of a "card" and a suitable mailing envelope, packaged for retail sale in a clear cellophane envelope. Each sample will be considered "goods put up in sets for retail sale" for tariff purposes, and will be classified on the basis of the component, the "card", which imparts the essential character to the set.

The card designated "Precious Box", Item EC 2253; the "Frog" card, item EC 2095; and the "Dog" card, item EC 4087, are folded paperboard cards, decorated on one or both outside faces, and, in the "Precious Box" card, decorated also on both inside faces.

All three have adequate space on the inside faces for the writing of messages, greetings, or the like, and they are by design intended to be so written in, and then mailed in the accompanying envelope.

The card designated "Dalmatian", item EC 2162, consists of two sheets of lithographically printed paper, cut out to the shape of a dog and printed with the spot markings of a Dalmatian dog, which are partially glued together at the upper body portion, so that the four legs may be separated by bending. This enables the dog to stand upright on a surface.

The Dalmatians muzzle has been slit, and a paper envelope measuring 1 3/4" x 3/4", bearing printed facsimile postage, is inserted in the slit, in such a way that he appears to be carrying a piece of mail in his mouth.

Neither the Dalmatian "card" figure nor the carried "envelope" contains space adequate or suitable for the writing of correspondence, greetings, etc.

The card designated "Black Cat", item EC 2272, is similar to the "Dalmatian" card in printing method, construction, and lack of interior (or exterior) space clearly suitable for correspondence. The applicable subheading for the cards discussed above as "Precious Box", "Frog", and "Dog" will be 4817.20.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for: Other (than certain enumerated) Envelopes, letter cards, plain postcards and correspondence cards, of paper or paperboard. The rate of duty is 1.6 percent.

The applicable subheading for the cards discussed above as "Dalmatian" and "Black Cat" will be 4911.91.2040, HTS, which provides for: Other printed matter, including printed pictures or photographs: Other (than trade advertising material, etc.): Pictures, designs and photographs: Printed not over 20 years at time of importation: Lithographs on paper or paperboard: Not over 0.51 mm in thickness: Other than posters. The rate of duty is 6.6 cents per kilogram.

(Subheading 4911.91.20 is one of several subheadings presently under consideration for temporary or conditional imposition of a rate of duty of 100 percent. This paragraph is advisory, only, and is not to be taken as an element of this ruling.) This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter 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 this ruling, contact National Import Specialist Carl Abramowitz, at (212) 637-7060. Sincerely,

Robert B. Swierupski

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