CLA-2-44:S:N:N8:230 811120

Ms. Rose Althoff
Midwest of Cannon Falls
32057 64th Avenue
P.O. Box 20
Cannon Falls, MN 55009-0020

RE: Tariff classification of wood display cabinets and calendar bear porcelain hinged boxes from Taiwan

Dear Ms. Althoff:

In your letter dated April 28, 1995, you requested a tariff classification ruling on goods described as follows: "Item: 16317-7 Calendar Bear Porcelain Hinged Boxes and Wood Display Cabinet." A sample was submitted.

The wood display cabinet measures 12 inches by 8 inches and 2 inches deep. The cabinet is divided into 12 compartments, and each compartment is labelled with a month of the year, January to December. The wood cabinet is intended to be hung on the wall using two hooks on its back.

The bear porcelain hinged boxes consist of a porcelain bear on top of a small porcelain box. Each bear depicts a motif for each month of the year. The bear porcelain boxes measure approximately 1-3/4 inches wide and 3-1/2 inches high.

You state that the porcelain bears will be marketed as collectible gift ideas to be displayed in the cabinet. Furthermore, the items will be purchased from your supplier as a single unit or "prepack" with one price; however, you indicate that your customers in the United States will likely sell the bear porcelain boxes as individual pieces of a collection. Your main concern in requesting this ruling is how the items will be classified when imported as a unit or "prepack".

Classification of goods under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that classification is determined first according to the terms of the headings of the tariff schedule and any relative Section or Chapter notes, and then, if the headings and notes do not otherwise require, in accordance with the remaining GRIs, taken in order. [GRI's 2 through 6.]

The Explanatory Notes (EN) to the HTS constitute the official interpretation of the tariff at the international level. The EN to GRI 3(b) define the expressions: "composite goods" and "goods put up in sets for retail sale".

The EN at page 4 under Rule 3(b) state as follows:

(IX) For the purposes of this Rule, composite goods made up of different components shall be taken to mean not only those in which the components are attached to each other to form a practically inseparable whole but also those with separable components, provided these components are adapted one to the other and are mutually complementary and that together they form a whole which would not normally be offered for sale in separate parts. (X) For the purposes of the Rule, the term "goods put up in sets for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are, prima facie, classifiable in different headings... (b) consist of products of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking (e.g., in boxes or cases or on boards). We do not believe that the bear porcelain boxes and the wood display cabinet can be considered a set or a composite article. The subject articles do not meet the criteria for composite goods or sets as the terms are defined in the cited Explanatory Notes.

The applicable subheading for the wood display cabinet will be 4420.90.8000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for wooden articles of furniture not falling within chapter 94. The rate of duty will be 4.7 percent ad valorem.

The applicable subheading for the bear porcelain hinged boxes will be 6913.10.5000, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for other statuettes and other ornamental ceramic articles of porcelain or china. 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