CLA-2-49:RR:NC:GI:234 A87054
Mr. Rene Debrunner
Vantage International Forwarding Ltd.
11222 La Cienega Boulevard, Suite 535
Inglewood, California 90304
RE: The tariff classification of a "pencil drawing kit" from Hong
Kong.
Dear Mr. Debrunner:
In your letter dated August 22, 1996, on behalf of Walter
Foster Publishing Inc., you requested a tariff classification
ruling.
A sample was submitted and will be retained for reference. It
is a retail display box containing a 32-page paperbound book
entitled "Pencil Drawing," a 6 1/2" x 9 1/2" pad of drawing paper,
six lead pencils (each with a different degree of hardness), a
vinyl eraser and a small, inexpensive pencil sharpener.
Several pages at the beginning of the book are devoted to text
and illustrations providing general information and guidance on how
to draw, with topics such as materials, hand positions,
perspective, textures and strokes. The balance of the book
consists of instructions for specific drawing "projects" which can
be undertaken using the materials provided in the kit.
With reference to General Rule of Interpretation 3(b),
Harmonized Tariff Schedule of the United States (HTS), we find that
this kit constitutes "goods put up in sets for retail sale," and
that its essential character is imparted by the book. The latter,
according to a breakdown included in your letter, is the most
costly component of the set. In addition, we note that the book
can continue to serve as a reference source even after the drawing
paper and pencils have been consumed.
Accordingly, the applicable subheading for the "pencil drawing
kit" will be 4901.99.0060, HTS, which provides for printed art and
pictorial books valued under $5 each. The rate of duty will be
free.
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 Carl Abramowitz at (212)
466-5733.
Sincerely,
Roger J. Silvestri
Director
National Commodity
Specialist Division