CLA-2-90:RR:NC:4:102 A82287

Mr. David A. Eisen
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway
43rd Floor
New York, New York 10036-8901

RE: The tariff classification of a thermometer with zipper pull keychain incorporating a thermometer and compass from either China or Taiwan

Dear Mr. Eisen:

In your letter dated April 8, 1996 you requested a tariff classification ruling.

A sample of the zipper pull keychain was submitted with your inquiry. The item is a key ring secured to a rectangular-shaped plastic attachment incorporating a miniature directional compass and a liquid-filled thermometer. The clear plastic covering the thermometer and compass is raised for easy reading. On the reverse side of the plastic attachment is a wind chill conversion chart. It is our opinion that none of the components impart the essential character of the article. Therefore, noting General Rule of Interpretation 3(c), we will classify it under the applicable HTS # that occurs last in the tariff.

The applicable subheading for the key ring combined with a thermometer and compass will be 9025.11.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for thermometers and pyrometers, not combined with other instruments, liquid-filled, for direct reading, other. The rate of duty will be 5 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 Karl J. Riedl at 212-466-5493.

Sincerely,

Roger J. Silvestri
Director
National Commodity
Specialist Division