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NY R03958




June 15, 2006

CLA-2-39:RR:NC:SP:221 R03958

CATEGORY: CLASSIFICATION

TARIFF NO.: 3926.90.9880

Ms. Jill Stavos
Target Customs Brokers, Inc.
33 S. 6th Street
Minneapolis, MN 55402

RE: The tariff classification of a plastic foam drawing mat from China.

Dear Ms. Stavos:

In your letter dated May 17, 2006, on behalf of Target Corporation, you requested a tariff classification ruling.

The submitted illustration depicts the Aquadoodle foam mat, no item number indicated. The foam mat can be drawn on with the included specialty pen. It is made of six foam squares with outer edges that are specially cut to interlock with each other. It has a border that also interlocks around the squares. The border is composed of ten pieces with interlocking shapes on the inner edges and straight edges on the outside. There are four rounded corner pieces with interlocking shapes on the inner edges. The border pieces have perforated shapes cut into them that a child can take out and put back like a puzzle or that the child can use to trace the shapes onto the center squares. The removable cutouts include shapes such as animals, flowers, a house, circle and triangle. An Aquadoodle pen is included with the foam mat. The pen is filled with water that causes the mat to change colors when drawn on. When the water dries, the drawings disappear and the child can draw some more.

This product is not considered to be a puzzle. For tariff purposes puzzles require only one possible answer or arrangement. These pieces are interchangeable and can be arranged in any order that suits the child.

The applicable subheading for the plastic foam mat and pen set will be 3926.90.9880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of plastics, other. The rate of duty will be 5.3 percent ad valorem.

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 Joan Mazzola at 646-733-3023.

Sincerely,

Robert B. Swierupski
Director,

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