The tariff classification of a Photo Bracelet, Photo Necklace and Photo Key Ring from China.

NY R02160 June 28, 2005 CLA-2-71:RR:NC:SP:233 R02160 CATEGORY: Classification TARIFF NO.: 7117.19.9000; 7326.20.0070 Mr. Karl Kane MYX, Inc. 300 Broadway Street Suite #30 San Francisco, CA 94133 RE: The tariff classification of a Photo Bracelet, Photo Necklace and Photo Key Ring from China. Dear Mr. Kane: In your letter dated June 18, 2005, you requested a tariff classification ruling. You have submitted pictures of the following items to be imported: MYX Photo Bracelet is a bracelet made of round plated plastic beads with smaller decorative beads made of spin cast metal. The beads are strung onto an elastic band. Attached to the bracelet is a small metal photo frame. The Photo Bracelet is also available with clear glass beads. The essential character of the bracelet is imparted by the metal component. MYX Photo Necklace is a necklace made of black tubular rubber or plastic. It has a clasp made of base metal with a small length of chain. The clasp and chain are nickel-chrome plated. Attached to the necklace is a small metal photo frame. The necklace is also available with in suede leather, in place of the black rubber tubing. The essential character of the necklace is imparted by the metal component. MYX Photo Key Ring is a ball key ring made of a steel rod bent into a C-shape. Metal balls screw onto the ends of the rod and hold keys onto the ring. Some of the decorated elements are chrome plated plastic, others are spin cast base metal chrome plated. All of these move freely along the metal ring. Attached to the key ring is a small photo frame. The frames attached to each of these items is made of base metal, spin cast (centrifugal casted), nickel-chrome plated. They range in size from 1 1/8” x ¾” (oval) to 1” x 1” (heart). The consumer can put a photograph into these frames by cutting it to the right size and snapping it into the frame under the tabs along with the clear acetate provided. The items are packaged in a clear acetate box for retail sale. The applicable subheading for the MYX Photo Bracelet and the MYX Photo Necklace will be 7117.19.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other.” The rate of duty will be 11% ad valorem. The applicable subheading for the MYX Photo Key Ring will be 7326.20.0070, HTS, which provides for “Other articles of iron or steel, articles of iron or steel wire, other.” The rate of duty will be 3.9% ad valorem. 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 Lawrence Mushinske at 646-733-3036. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division