CLA-2-84:RR:NC:1:110 B87626

Mr. A. Arndt
Team Concepts North America, Ltd.
331 Eisenhower Lane South
Lombard, Illinois 60148

RE: The tariff classification of a laptop learning device from China.

Dear Mr. Arndt:

In your letter dated July 8, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves a model # A0725 "ComQuest Scholar" device which is designed to allow children to type memos and reports. This personal laptop learning device is approximately 10 1/4 inches in length by 8 1/4 inches in width, and has a height of 1 5/8 inches. It consists of a standard typewriter keyboard which includes special function keys. These function keys include various activities such as "Game Code", "Record", "Repeat", and "Title Text". It incorporates built-in memory for saving and storing documents.

The "ComQuest Scholar" device is age graded for kids 6 and above. There are built-in educational games and activities in math, spelling, grammar and more. Also built-in is a mini word processor with a complete spell check as well as the ability to hook up to a plain paper printer so kids can print reports, messages, and pictures. There are 40 total built-in activities. This composite machine has the ability to perform word processing, storage, data retrieval, and game functions. The principal use of the "ComQuest Scholar" appears to be its word processing capacity. NY Ruling Letter B86269 was the subject of a similar device. The applicable subheading for the model number A0725 "ComQuest Scholar" device will be 8469.11.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for automatic typewriters and word processing machines. The rate of duty will be 0.6 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 Art Brodbeck at 212-466-5490.

Sincerely,

Robert B. Swierupski
Chief, Metals & Machinery Branch
National Commodity
Specialist Division