CLA-2-95:S:N:N3D:225 856643

Ms. Jill M. Ross
A.W. Fenton Company, Inc.
6565 Eastland Road
Cleveland, Ohio 44142-1388

RE: The tariff classification of various toys from Hong Kong

Dear Ms. Ross:

In your letter dated September 24, 1990, you requested a tariff classification ruling on behalf of Cap Toys, Inc.

Four samples were submitted with your inquiry. The first item number 2050, is called a "Sqwish Jump Rope". The rope portion is made of a clear PVC plastic with multi-colored glitter suspended inside. The handles at each end are made of 80% nylon and 20% Spandex material, which conceals a non-toxic plastic gelatin, covered with a tough latex bladder. The handles are soft and round in shape and will return to their original form after being squeezed.

Item number 5030, is referred to as a "Giant Bubble Gun". The gun is approximately 7 inches long, made of plastic and has a barrel resembling three colored balls with a traditional hand trigger. When the trigger is pulled a burst of air is blown through the barrel to the tip which holds the bubble liquid. It has the ability to blow huge bubbles or millions of small ones depending on how quickly the trigger is pulled. The gun operates on two "AA" batteries which will not be included in the package.

The next item number 2030, is called a "Sqwish Dish", described as a flying disc for indoor or outdoor play. It is made of 80% nylon and 20% Spandex material. Inside is a non- toxic plastic gelatin, covered by a tough latex bladder. The disc is soft and very flexible and when propelled, simulates a Frisbee flying toy.

The last article, item number 2040, is known as "Sqwish Sqwash". It resembles a mini trampoline in appearance but is used as a ball bouncer. A 10 inch diameter surface made of nylon/spandex material covers a round plastic rim. Two swivel- hinged handles are attached. The applicable subheading for all of the above named articles will be 9503.90.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other toys (except models), not having a spring mechanism. The duty rate will be 6.8 percent ad valorem. 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