CLA-2-49:S:N8:234 804702

Mr. Paul S. Anderson
Sonnenberg, Anderson & Rodriguez
200 South Wacker Drive, 33rd Floor
Chicago, Illinois 60606

RE: The tariff classification of "Sounds by Me" Recordable Book, from the Peoples Republic of China.

Dear Mr. Anderson:

In your letter dated November 29, 1994, on behalf of your client, Western Publishing Company, Inc., Racine, Wisconsin, you requested a tariff classification ruling. Samples were submitted, which will be retained for reference. The merchandise in question consists of illustrated children's books, each of which has an electronic sound module along its back binder, affixed so as to appear alongside the text. Each sound module has eight touch pads that correspond to illustrations and symbols in the book.

Two of the touch pads have pictures and pre-recorded sounds, e.g., a picture of a cuckoo clock and a picture of a key winding a clock. The remaining six touch pads have various symbols and allow the child to record sounds of the child's making for incorporation into the story line. The books provide instructions as to how to record the sound and specify the type of sound, name or information that is to be recorded on each one of the touch pads.

The applicable subheading for the "Sounds by Me" recordable book will be 4901.99.0070, Harmonized Tariff Schedule of the United States (HTS), which provides for: Other (than certain enumerated printed books): Hardbound books. The rate of duty will be Free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director
New York Seaport