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NY L86633




August 3, 2005

CLA-2-95:RR:NC:SP:225 L86633

CATEGORY: CLASSIFICATION

TARIFF NO.: 9503.90.0080

Ms. Joanne Harmon
CVS/Pharmacy
One CVS Drive
Woonsocket, RI 02895

RE: The tariff classification of a Talk ‘n Learn assortment from China.

Dear Ms. Harmon:

In your letter dated July 25, 2005, you requested a tariff classification ruling.

You submitted a sample of a Talk ‘n Learn assortment identified as assortment number 318728, which is being retuned upon your request.

The Talk ‘n Learn assortment is comprised of Talk ‘n Learn Alphabet and Talk ‘n Learn Numbers, which are plastic square-shaped electronic educational toys designed to amuse while helping pre-school children learn the alphabet and learn how to count numbers. Each electronic toy measures approximately 1-1/2” in height x 7-1/4” in width x 9-1/4” in length, and features play buttons, a “try me” button, an activity selector, talk and music modes, a built-in speaker, and a carrying handle.

The Talk ‘n Learn Alphabet features 26 letter buttons on its surface, along with pictorial representations next to each letter. For example, the letter “A” also has a picture of an airplane. The letter “B” has a picture of a banana. The letter “C” has a picture of a cow, etc. When the letter “A” is pressed, a pre-recorded voice pronounces the letter “A.” Pressing the other letter buttons results in similar voiced pronunciations of those letters as well, which encourages the child to repeat along. By moving the selector switch, a child can also listen to an assortment of 27 nursery rhymes accompanied by music. The Talk ‘n Learn Numbers functions the same as the Talk ‘n Learn Alphabet except that numbers are on the surface of the toy instead of letters.

The Talk ‘n Learn Alphabet and Talk ‘n Learn Numbers provide amusement via songs and music even if no learning takes place. The items will be packaged individually in cardboard boxes with window displays.

The applicable subheading for the Talk ‘n Learn assortment (Talk ‘n Learn Alphabet and Talk ‘n Learn Numbers) identified as assortment number 318728 will be 9503.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for "Other toys; reduced-size ("scale") models and similar recreational models, working or not; puzzles of all kinds; parts and accessories thereof: 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 Alice Wong at 646-733-3026.

Sincerely,

Robert B. Swierupski
Director,

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