CLA-2-84:RR:NC:1:103 D89205

Mr. George Ciesek
Graffitti Graphics
912 Lyall Street
Victoria, B.C., Canada V9A 5E6

RE: The tariff classification of a jigsaw puzzle press and associated items from Canada

Dear Mr. Ciesek:

In your letter dated March 3, 1999 you requested a tariff classification ruling.

You intend to export to the United States an equipment package consisting of an electrically powered jigsaw puzzle press, three steel rule dies, a container holding 2.5 gallons of glue, 20 advertising display signs, and an instructional videotape. This package will be marketed to home-based businesses for use in selling jigsaw puzzles produced from personal photographs. The photograph is initially enlarged by means of a color photocopier. The operator then glues the enlargement to a cardboard backing and places it face down, along with the appropriate steel rule die, in the puzzle press. As the die and glued photocopy are pulled through the press a pair of rollers exerts pressure on the die, causing it to cut the picture and backing into jigsaw pieces.

The steel rule dies measure 4 inches by 6 inches, 8.5 inches by 11 inches, and 11 inches by 17 inches, and are used to produce 24 piece, 48 piece, and 308 piece puzzles respectively. The jigsaw press itself has dimensions of 24 inches by 26 inches by 27 inches, and weighs 420 pounds. The display signs are printed plastic sheets 24 inches by 18 inches which may be placed in retail locations for promotional purposes.

The applicable subheading for the jigsaw puzzle press will be 8441.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for cutting machines for pulp, paper or paperboard. The duty rate will be free.

The applicable subheading for the steel rule dies will be 8208.90.6000, HTS, which provides for knives and cutting blades, for machines or for mechanical appliances, and base metal parts thereof: other: other. The duty rate will be free. The applicable subheading for the display signs will be 4911.10.0080, HTS, which provides for other printed matter, including printed pictures and photographs: trade advertising material, commercial catalogs and the like. The rate of duty will again be free.

Finally, the applicable subheading for the instructional videotape will be 8524.53.10, HTS, which provides for records, tapes and other recorded media for sound or other similarly recorded phenomena...: other magnetic tapes: of a width exceeding 6.5 mm: video tape recordings. The rate of duty will also be free.

Your inquiry does not provide enough information for us to give a classification ruling on the glue. Your request for a classification ruling should include a statement as to the composition of the glue (e.g., plastic or rubber based), and its weight.

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 Alan Horowitz at 212-637-7027.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division