CLA-2-95:RR:NC:SP:225 F83422

9102.12.8000; 9102.12.4000

Ms. Jennifer F. Kessinger
Katten, Muchin & Zavis
525 West Monroe St., Suite 1600
Chicago, IL 60661-3693

RE: The tariff classification of a toy puzzle-lock, a plastic animal figure, a hair scrunchie, and a digital watch and watch band from China

Dear Ms. Kessinger:

In your letter dated March 2, 2000, received in this office on March 7, 2000, you requested a tariff classification ruling on behalf of The Marketing Store Worldwide.

The four submitted samples are associated with the “Hello Kitty” line of promotional products. The “apple-puzzle-lock” is a plastic child’s play lock that resembles an apple. It measures 2 ¾” in height. The red apple is printed with four pictures of the “Hello Kitty” character wearing different outfits. The apple portion is divided into five horizontal sections that turn like a cylinder lock. When the puzzle is aligned correctly, the green stem portion at the top of the apple “unlocks”. In reality, this stem never securely locks into the apple and may be opened even when the puzzle is misaligned. The article is designed for amusement purposes and does not function as a real lock.

The “Hello Kitty” sticker dispenser measures approximately 3” in height. The dispenser resembles the full-bodied figure of the “Hello Kitty” character. The plastic animal figure contains a roll of stickers within its body cavity. A flap at the base of the cat lifts up for removal of the stickers. In a phone conversation, you had stated that the sticker dispenser is non-refillable. Therefore, when the stickers are used up, one is left with an amusing cat figure.

The “Hello Kitty” ponytail scrunchie is constructed of a knit textile fabric enclosing an elastic band. The article features a stuffed “Hello Kitty” character figure that has been sewn on. The item is designed primarily to hold the hair in place.

The “Hello Kitty” watch consists of a plastic wristband and a non-removable plastic “charm” that contains an LCD watch. The wristband simply snaps onto the wearer with no form of closure. It contains a raised plastic loop designed to hold the attached charm. The charm depicts the face of the “Hello Kitty” character. The reverse side of the face reveals an LCD digital watch with time and date features. Adjustment knobs are located at either side of the charm.

The applicable subheading for the “Hello Kitty” apple-puzzle-lock will be 9503.60.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for other toys: puzzles and parts and accessories thereof: other. The rate of duty will be free.

The applicable subheading for the “Hello Kitty” sticker dispenser will be 9503.49.0025, Harmonized Tariff Schedule of the United States (HTS), which provides for toys representing animals or non-human creatures: other: toys. The rate of duty will be free.

The applicable subheading for the “Hello Kitty” ponytail scrunchie will be 6117.80.8500, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other made up clothing accessories, knitted or crocheted; knitted or crocheted parts of garments or of clothing accessories: Other accessories: Other: Headbands, ponytail holders and similar articles.” The rate of duty will be 15% ad valorem.

The applicable subheading for the “Hello Kitty” watch will be 9102.12.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, pocket watches and other watches, including stop watches, other than those of heading 9101; wrist watches, battery operated, with opto-electronic display only. The rate of duty will be free.

The applicable subheading for the “Hello Kitty” plastic watch band will be 9102.12.4000, (HTS), which provides for other straps, bands or bracelets entered with watches of subheading 9102.12.80 and classifiable therewith pursuant to additional U.S. note 2 to this chapter; all the foregoing whether or not attached to such watches at the time of entry; other. The rate of duty will be free.

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 Alice J. Wong at 212-637-7028.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division