CLA-2-49:RR:NC:SP:234 C89433

Ms. Maggie Smith

Coppersmith, Inc.

1599 Grandview Drive

So. San Francisco, CA 94080

RE: The tariff classification of a book printed in Singapore accompanied by toy construction parts from Denmark.

Dear Ms. Smith:

In your letter dated April 22, 1998 (resubmitted June 18, 1998) you requested a tariff classification ruling on behalf of your client, Klutz, Inc.

A sample was submitted and will be retained for reference. It is a 66-page spiral-bound children's book, entitled "LEGO Crazy Action Contraptions," which includes an attached plastic pouch containing 60 LEGO "technic pieces" (small plastic gears, beams, axles, etc., for toy construction projects) and six rubber bands. The first 25 pages of the book are printed with illustrated text instructing the reader on how to build five different toy "contraptions" using only the parts provided. The remaining pages contain instructions for five other projects which require the reader to furnish additional components and/or materials, such as standard LEGO bricks, string, etc.

For tariff purposes, the above-described merchandise will be considered "goods put up in sets for retail sale" whose essential character is imparted by the book.

Accordingly, the applicable subheading for the complete "LEGO Crazy Action Contraptions" set will be 4901.99.0093, Harmonized Tariff Schedule of the United States (HTS), which provides for other (than certain enumerated) printed books containing 49 or more pages each. The rate of duty will be free.

We note that the back of the book's front cover contains copyright and trademark information, cautionary statements, and general information about your client's business, including its California address. No country-of-origin information appears on this page. The origin information instead appears near the back of the book, on a page largely devoted to credits for photography, design, modeling, etc. The following words appear at the bottom of that page: "This book was manufactured in Singapore. LEGO components made in Denmark."

Since a prospective purchaser would more likely look at the front copyright page than at a page near the back for information about the book, he/she might in this instance be misled or deceived as to the actual country of origin. (See 19 C.F.R. ยง134.46) To avoid related difficulties with Customs at the time of entry, it is suggested that the origin statements be placed in close proximity to the U.S. address on the front copyright page, in lettering of comparable size.

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 Carl Abramowitz at 212-466-5733.


Robert B. Swierupski


National Commodity

Specialist Division