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NY J81871




March 10, 2003

CLA-2-95:RR:NC:SP:225 J81871

CATEGORY: CLASSIFICATION

TARIFF NO.: 9503.70.0000

Mr. Joel K. Simon
Serko & Simon LLP
Customs & International Trade Law
1700 Broadway, 31st Floor
New York, NY 10019

RE: The tariff classification of “Baby’s First Wallet” from China.

Dear Mr. Simon:

In your letter dated March 5, 2003, on behalf of your client, Sassy Inc., you requested a tariff classification ruling.

The sample submitted, Product #228, “Baby’s First Wallet”, consists of a brightly colored (yellow, green red, purple, and orange) textile fabric tri-fold wallet that measures approximately 4 inches in height and 3-1/8 inches across when closed and 4 inches in height and 9-3/8 inches across when opened. It has one center compartment and various open pockets, photo pocket, a pocket with a hook and loop closure and a zippered pocket designed to accommodate 3 chewy oversized cards (a credit card, a “stroller license” and a “push-out” puzzle. Also included, is an oversized plastic key ring that holds colorful coin-like discs numbered 1, 2, 3 and two plastic keys.

According to the advertising copy for this product, the item is a toy targeted for an infant 9 months and older that provides visual stimulation (the allure of brightly colored objects), manual and aural stimulation (chewy cards and a key chain with keys and discs that rattle), and encourages the development of manipulative skills when the infant inserts and removes articles from the wallet.

Provided that the instant merchandise is packaged together for retail sale, this office concurs that the instant merchandise is a toy set that provides manipulative role-play and frivolous amusement for an infant carrying out the adult activities of using a wallet, keys and coins.

The applicable subheading for Product #228, “Baby’s First Wallet”, will be 9503.70.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other toys, put up in sets or outfits, and parts and accessories thereof.” 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 Alice Wong at 646-733-3026.

Sincerely,

Robert B. Swierupski
Director,

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