CLA-2-49:OT:RR:NC:2:234
Mr. John A. Whitson
Costco Wholesale Corporation
999 Lake Drive
Issaquah, WA 98027
RE: The tariff classification of a printed play mat from South Korea
Dear Mr. Whitson:
In your letter dated April 10, 2012, you requested a tariff classification ruling.
The ruling was requested on the Children’s PVC Interactive Play Mat identified as Costco item number 925551. You submitted four photos of the item for our examination. The interactive play mat is constructed of 100% polyvinyl chloride (PVC) foam plastic material. The play mat measures approximately 82.7” (l) x 55.1” (w) x .51” (d).
The interactive play mat is reversible and serves a dual purpose as an educational learning resource and a decorative floor covering. It is printed on both sides with bright colors and illustrations that depict letters, numbers and objects. One side of the mat is designed with representative pictures and words to correspond with each letter of the alphabet. The opposite side of the play mat is illustrated with a play scene that identifies various animal figures. This play mat is used as an interactive educational learning resource to engage a young child and to encourage the recognition of letters, words, and numbers. The play mat is designed for use by children ages 0 – 7 years old.
You suggest classification of the Children’s PVC Interactive Play Mat (Costco item number 925551) as a toy under 9503.00.0071, HTSUS. You state that the mat is an “interactive learning item that would be played on with a child and parent to learn the letters of the alphabet and animals.” However, the item is not principally designed for amusement as the decorative mat provides the utilitarian function of covering the floor. Furthermore, the item lacks any manipulative play value.
The applicable subheading for the PVC Interactive Play Mat will be 4911.99.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other printed matter, including printed pictures and photographs: Other: Other: Other: Other. The rate of duty will be Free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
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 Albert Gamble at (646) 733-3037.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division