CLA-2-90:RR:NC:MM:114 K87477

Mr. Joseph R. Hoffacker
Barthco Trade Consultants
7575 Holstein Avenue
Philadelphia, PA 19153

RE: The tariff classification of Drawing Center made in China

Dear Mr. Hoffacker:

In your letter dated June 21, 2004, on behalf of K.B. Toys of Massachusetts, Inc., you requested a tariff classification ruling on the Drawing Center made in China. A sample of the Drawing Center was submitted with the ruling request.

The submitted item number 91002 is identified as the Drawing Center. The Drawing Center includes 1 projector, 30 image discs, 4 sheets of art line drawing paper, 8 sheets of fuzzy paper, 2 envelopes, 2 flow cards, 12 color pencils, 12 water colors, 8 sheets of white paper, 8 sheets of translucent paper, 5 packs of color glitter, 1 pencil, 2 brushes, 1 plastic stencil, 1 eraser, 1 glue, 1 scissors and 2 small tools. The portable drawing projector is housed in a molded plastic case with handle. The user is instructed to insert an image disc, and the image will be projected onto the drawing surface. The instructions indicate which buttons to press to move the light-up images to desired positions. The Drawing Center uses 4 size C batteries 1.5 V, which are not included. The Drawing Center is packed in a cardboard box ready for retail sale. Your sample is being returned as requested.

The applicable subheading for the Drawing Center will be 9008.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for image projectors, other than cinematographic; other image projectors. The rate of duty will be 4.6 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 Barbara Kiefer at 646-733-3019.


Robert B. Swierupski
National Commodity
Specialist Division