CLA-2-95:S:N:N8:225 802508
Mr. Herb Sternberg
Herbko
301 W. Hallandale Beach Blvd.
Hallandale, Florida 33009
RE: The tariff classification of a crossword puzzle with holder
and refills from China
Dear Mr. Sternberg:
In your letter dated September 20, 1994, received in this
office on September 27, 1994, you requested a tariff classifi-
cation ruling.
Your inquiry involves two items for which you have submitted
a complete description and advertising literature. Item #3800,
"Crossword Companion", consists of an injection molded plastic
holder, four paper rolls printed with crossword puzzles and one
pencil (of U.S. origin). The plastic holder contains two
cylindrical reels and a storage drawer with built in pencil
sharpener. The roll of crosswords is placed on one reel and
extended to a receiving reel. The receiving reel may be turned
by the user to advance to the next puzzle. In addition to
storing the pencils and puzzle rolls, the holder provides a
sturdy surface, upon which, the user may complete the puzzle.
According to your letter the plastic holder is designed
exclusively for use with the crossword puzzle rolls. Item
#38111, "Crossword Puzzle Refill", consists solely of printed
crossword puzzles on paper rolls.
Classification is based upon the General Rules of Interpre-
tation. Item #3800, "Crossword Companion", is considered a set
for classification purposes. GRI 3(b) states in part that "goods
made up of different components which cannot be classified by
reference to 3(a), shall be classified as if they consisted of
the material or component which gives them their essential
character". This office finds the essential character of the
subject article to be imparted by the crossword puzzle. The
plastic holder simply facilitates use of the puzzle rolls.
The applicable subheading for item #3800, "Crossword
Companion" and item #38111, "Crossword Puzzle Refill", will be
9503.60.1000, Harmonized Tariff Schedule of the United States
(HTS), which provides for other toys: puzzles and parts and
accessories thereof: crossword puzzle 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.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport