The tariff classification of electronic learning devices from China

N116536 August 4, 2010 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8543.70.9650 Dennis Morse BDP International, Inc. 2721 Walker Avenue N.W. Grand Rapids, MI 49504 RE: The tariff classification of electronic learning devices from China Dear Mr. Morse: In your letter dated July 21, 2010, you requested a tariff classification ruling. The samples which you submitted are being returned to you as requested. The first item concerned is the Alphabet Apple (Item #80-101000). This is a portable multi-functional electronic learning device specifically designed for children ages 3 years and up. It measures approximately 12 inches wide by 10 ½ inches long by 1 ¾ inches thick. The housing is made of plastic and incorporates a handle to make the item portable. The item contains alpha-numeric buttons, a moveable clock hand and an activity selector. The item operates on three “AA” batteries. The Alphabet Apple (Item #80-101000) uses pictures images, sounds and various activities to teach children phonics, time, animals and music. The second item concerned is the ABC Text & Go (Item #80-116600). This is a portable multi-functional electronic learning device specifically designed for children ages 3 years and up. It measures approximately 4 ¼ inches wide by 6 ½ inches long by 1 ¼ inches thick. The housing is made of plastic and the item is portable. It consists of a liquid crystal display (LCD) screen, a QWERTY keyboard, arrow and enter buttons and 8 activity buttons. The system operates on 3 “AA” batteries. The ABC Text & Go (Item #80-116600) uses animated graphics, sounds and various activities to teach children letters, words, numbers and counting. The Tote & Go Laptop (Item #80-067800) is a portable multi-functional electronic learning device specifically designed for children ages 3-6 years old. It measures approximately 9 inches wide by 8 ¾ inches long by 2 ¼ inches thick when closed. The housing is made of plastic and incorporates a handle to make the item portable. It consists of a liquid crystal display (LCD) screen, a speaker, QWERTY keyboard, a moveable mouse, letter and number keys and four category buttons. The Tote & Go Laptop (Item #80-067800) uses animated graphics, sounds and various activities to teach children vocabulary, math, mouse skills, logic and puzzles. The applicable subheading for the Alphabet Apple (Item #80-101000), the ABC Text & Go (Item #80-116600) and the Tote & Go Laptop (Item #80-067800) will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6%. 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 Steven Pollichino at (646) 733-3008. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division