The tariff classification of a combination ruler/calculator from China.

N012726 July 12, 2007 CLA-2-84:RR:NC:1:110 CATEGORY: Classification TARIFF NO.: 8470.10.0040 Mr. Donald S. Stein Greenberg Traurig, LLP Attorneys at Law 800 Connecticut Ave., NW Suite 500 Washington, DC 20006 RE: The tariff classification of a combination ruler/calculator from China. Dear Mr. Stein: In your letter dated June 8, 2007, you requested a tariff classification ruling on behalf of your client, BIC Graphic USA, a division of BIC USA Inc. (“BIC”). The merchandise under consideration is the BIC Combination Ruler/Calculator. The submitted sample is an eight-inch ruler measuring approximately two inches wide, constructed of clear plastic with a scale of inches on one edge and centimeters on the opposite. A blue transparent plastic calculator measuring approximately eight-inches long by one and three-sixteenths of an inch is inserted into the center of the ruler. This calculator is battery powered and features an eight-digit Liquid Crystal Display (LCD) screen measuring approximately one and one-half inches by three-quarters of an inch, 24-button full function numeric keyboard with 3-key memory (i.e. MRC, M-, M+), On, Off and Clear keys. The Ruler/Calculator is a composite good made up of different components classified under different headings. The General Rules of Interpretation (GRI) of the Harmonized Tariff System (HTSUS), in particular, GRI 3(b) provides, in relevant part, that composite goods, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character. The factors which determine essential character will vary as between kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. From the information provided with this ruling request, the calculator clearly provides the essential character of this item. The applicable subheading for the BIC Combination Ruler/Calculator will be 8470.10.0040, HTSUS, which provides for “Calculating machines and pocket-size data recording, reproducing and displaying machines with calculating functions…Electronic calculators capable of operating without an external source of electric power…Display only.” The general 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 Thomas Campanelli at 646-733-3016. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division