CLA-2-73:RR:NC:N1:113 J84504

Mr. Kenneth L. Stambler
Specialty House of Creation
1568 Jesse Bridge Road
Pittsgrove, NJ 08318

RE: The tariff classification of slot machine card holders from China

Dear Mr. Stambler:

In your letter dated May 6, 2003, you requested a tariff classification ruling.

The samples you submitted are two card holders used with casino slot machines. Item number 2188 is the Jackpot style, and item number 8188 is the Slot Claw style. Both styles consist of a 12-inch plastic bungie coil with a steel wire split ring connected to each end. Attached to one split ring is a small plastic clip that is shaped like a slot machine and imprinted with casino advertising. The clip will be fastened to a purse, belt, or other article of clothing. The player will attach his casino club membership card to the other split ring. When playing a slot machine, the gambler inserts the casino card into the machine, thereby allowing the casino to track his betting for marketing and promotional purposes. The product also ensures that the player will not leave his card behind in a slot machine. In your letter, you suggest classification under HTS 9504.30.0060. However, in the opinion of this office, the card holder does not meet the criteria for classification as parts or accessories to coin game machines. The card holder does nothing to enhance the play of the slot machine or contribute to the operating efficiency of the machine.

The applicable subheading for the slot machine card holders will be 7326.20.0070, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem.

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 James Smyth at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division