Aug. 1, 1990
Mr. Allan H. Kamnitz
Sharretts, Paley, Carter & Blauvelt
Sixty-seven Broad Street
New York, NY 10004
RE: The tariff classification of a Playtime "Holly Hobbie Flower
Design Jewelry Making kit" from China.
In your letter dated July 18, 1990, on behalf of Playtime
Products, Inc., you requested a tariff classification ruling.
The submitted sample, style number 9901, is a "Holly Hobbie
Flower Design Jewelry Making Kit" containing 865 pieces or parts
including two metal spring clasps, two metal jump rings, nylon
bead string cord and 865 plastic beads for assembly into "Daisy
Chain" necklaces and bracelets. The kit is intended for children
(ages 6 and up). The value of the kit is $3.30 each.
Your sample is being returned per your request.
The 865 parts in the kit constitute an unassembled imitation
jewelry article within the scope of HTS subheading 7117.90.40,
noting General Rule of Interpretation 2(a) Harmonized Tariff
Schedule of the United States (HTS), which states:
"Any reference in a heading to an article shall be taken to
include a reference to that article incomplete or unfinished,
provided that, the incomplete or unfinished article has the
essential character of the complete or finished article. It
shall also include a reference to that article complete or
finished (or falling to be classified as complete or finished by
virtue of this rule), entered unassembled or disassembled."
The applicable subheading for the Playtime "Holly Hobbie
Flower Design Jewelry Making Kit", style number 9901, will be
9902.71.13, HTS, which provides for jewelry provided for in
subheading 7117.19.10, 7117.19.50 or 7117.90.40 (except parts)
valued not over 1.6 cents per piece. The rate of duty will be
The proviso "except parts" does not apply with respect to
the subject imitation jewelry kit because, for purposes of HTS
subheading 9902.71.13, and as stated previously concerning
7117.90.40, the unassembled parts or pieces of the Playtime 9901
kit constitute an unassembled entirety--an imitation jewelry
article. The restriction is intended for individual parts or
findings that do not make up an entirety.
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
Jean F. Maguire
New York Seaport