The tariff classification of "Letter Hunt" from China.

NY J84928 May 28, 2003 CLA-2-95:RR:NC:SP:225 J84928 CATEGORY: Classification TARIFF NO.: 9503.90.0080 Ms. Jean Hillan Traffic Manager Innovative Kids 18 Ann Street Norfolk, CT 06854 RE: The tariff classification of “Letter Hunt” from China. Dear Ms. Hillan: In your letter dated May 19, 2003, you requested a tariff classification ruling. You have submitted a sample of “Letter Hunt” identified as ISBN: 1-58476-205-5. The item consists of a book that measures approximately 11 inches in height and 9-1/2 inches in width and contains ten pages of memory match activities designed for children 3-7 years of age. All of the activities involve images hidden under cardboard flaps. For example, one game displays each letter of the alphabet on the outside of a lift up cardboard flap. After the child pronounces the letter he/she lifts up the flap and sees an image starting with the letter just sounded-out. For example, under the letter “R” would be a picture of a radio. The child then pronounces the word “radio.” Another activity depicts images (animals, food, clothing, etc.) on the outside flaps for the child to pronounce while underneath the flaps are the starting letters for the image on the outside of the flap. For example, under a picture of a tiger would be a capital “T” and a small “t”. There is also a rhyming activity whereby a child sees an object (i.e. a bat) and finds an image on the opposite page that rhymes with bat (i.e. cat). There is also a page of flaps with nothing underneath them and a page of images that can be “punched out” so that the child can create his/her own memory match activity. In our opinion, the item is an educational toy designed to encourage learning with manipulative play as a child lifts a game flap to see what is underneath it. The child would derive amusement from this activity even if no learning takes place. Your sample is being returned upon your request. The applicable subheading for the “Letter Hunt” identified as ISBN: 1-58476-205-5 will be 9503.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other toys; reduced-size ("scale") models and similar recreational models, working or not; puzzles of all kinds; parts and accessories thereof: Other: Other.” 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 Alice Wong at 646-733-3026. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division