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NY M84580




July 13, 2006

CLA-2-85:RR:NC:1:108 M84580

CATEGORY: CLASSIFICATION

TARIFF NO.: 8520.90.0080

Mr. Karl F. Krueger
DHL Danzas Air & Ocean
2660 20th Street
Port Huron, MI 48060

RE: The tariff classification of a talking book from China.

Dear Mr. Krueger:

In your letter received in this office on June 21, 2006, on behalf of Cranium, Inc., you requested a tariff classification ruling.

The submitted sample, which is known as the Talking Picture Book, is a battery-operated, talking book-like device that essentially combines a storybook with a voice recorder. This article consists of a plastic board, measuring nearly 11 inches long by 10 inches wide, that serves as the backing for a spiral-bound book with blank plastic-coated paperboard paper serving as reusable pages; there are also several pages that hold printed-plastic static-cling stickers of story-related depictions, as well pages for starting and trouble-shooting instructions. The voice recorder, incorporated in the board and situated laterally to the book, has a record/play slide-switch mechanism, as well as four numbered control buttons with each operating to both record and reproduce story-related words and sounds in correlation with the complete-depicted page. Across the board’s top portion, it features the following: a built-in spinner with a slot-like opening for accommodating its printed paperboard disks, which depict story-starter ideas; a built-in receptacle with removable eraser; and specially designed holders with removable markers.

It has been determined, based on General Rule of Interpretation 3 (c), that the subject composite article is classified in the heading (in this instance, 8520) which occurs last in numerical order among those which equally merit consideration.

The applicable subheading for this talking book will be 8520.90.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Magnetic tape recorders and other sound recording apparatus, whether or not incorporating a sound reproducing device: Other Other. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Michael Contino at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,

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