CLA-2-85:OT:RR:NC:N1:112

Dennis Morse
BDP International, Inc.
2721 Walker Avenue N.W.
Grand Rapids, Michigan 49504

RE: The tariff classification of the Baby’s Learning Laptop from China

Dear Mr. Morse:

In your letter dated November 2, 2010, you requested a tariff classification ruling on behalf of your client, Meijer Distribution. The sample is being returned as requested.

The item concerned is the “Baby’s Learning Laptop” (model number 80-073800). This is a multi-functional electronic learning device designed for children ages 6 months and older.

The “Baby’s Learning Laptop” (model number 80-073800) is a portable, battery operated handheld electronic device. The housing is made of plastic and measures approximately 10 inches long x 8 inches wide x 3 inches deep when closed. This device is hinged along one side. When flipped opened, one side incorporates a light up screen with permanent graphics that measures approximately 5 ½ inches x 3 1/2 inches. Located on the other side of the device is a power/volume button, nine differently shaped action buttons, a mode selector and a permanently affixed movable mouse. A battery compartment is located within the back of the item. The system operates on 2 “AA” batteries which are included.

The “Baby’s Learning Laptop” (model number 80-073800) uses permanent graphics, sounds, buttons, and lights to teach children shapes, sounds, and picture recognition.

The applicable subheading for the “Baby’s Learning Laptop” (model number 80-073800) will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6%.

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 Steven Pollichino at (646) 733-3008.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division