CLA-2-85:RR:NC:MA: 112 A85259
Ms. Regina M. Bernard
1027 Newport Avenue
P.O. Box 1059
Pawtucket, RI 02862-1059
RE: The tariff classification of the "Explore N Play U.S.A." from Mexico, and individual components from China
Dear Ms Bernard:
In your letter dated June 24, 1996 you requested a tariff classification ruling.
As indicated by the submitted samples, the "Explore N Play U.S.A." consists of a battery operated interactive device housed in a rectangular plastic case with a built-in handle. The user can interact with this item by pressing various points on a surface mounted map, and receiving feedback in the form of speech, music and sound effects.
The individual components consist of a "captive U.S.A. map", a module assembly, backup plate, and sensor keypad. The map is a representation of the United States, and contains symbols and figures which are used during the interaction process. The module assembly consists of an integrated unit incorporating the activation button, sound producing apparatus, a printed circuit board, and a battery holder. The backup plate is a plastic strip which holds the map and sensor keypad in place. The sensor keypad is a flexible circuit board located beneath the map. It transmits electrical signals to the module assembly when pressure is applied to the map.
The applicable tariff provision for the "Explore N Play U.S.A." will be 8543.89.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for electrical machines and apparatus, ..., not specified or included elsewhere in Chapter 85, HTS. The general rate of duty will be 3.4 percent ad valorem.
The applicable tariff provision for the "captive U.S.A. map" will be 4911.91.2040, HTS, which provides for other printed matter: lithographs on paper or paperboard, not over 0.51 mm in thickness, other. The rate of duty will be $.106 per kilo.
The applicable tariff provision for the module assembly and backup plate will be 8543.90.7580, HTS, which provides for other parts of electrical machines and apparatus, ..., not specified or included elsewhere in Chapter 85, HTS. The rate of duty will be 3.4 percent ad valorem.
The applicable tariff provision for the sensor keypad will be 8538.90.2000, HTS, which provides for printed circuit assemblies for use solely or principally with the apparatus of heading ... 8537. The rate of duty will be 4.6 percent ad valorem.
You have also inquired as to whether the marking "Assembled in Mexico from Chinese and USA Components" is acceptable for the "Explore N Play U.S.A." Based on the assembly process undertaken in Mexico, and in light of recent modifications to 19 CFR 134.43(e), this office believes that such marking is acceptable.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 David Curran at 212-466-5680.
Roger J. Silvestri