CLA-2-73:RR:NC:1:115 B89587

Mr. Arlen T. Epstein
Serko & Simon
One World Trade Center
Suite 3371
New York, NY 10048

RE: The tariff classification of a key chain and a key ring from China and South Korea.

Dear Mr. Epstein:

In your letter dated September 11, 1997, you requested a tariff classification ruling, on behalf of Russ Berrie and Company, Inc, Oakland, NJ. Your submitted samples will be returned to you as requested. The subject items are described as follows: 1) Stuffed miniature jointed teddy bear key chain, item 1813 - which is comprised of a 2 3/4" long teddy bear attached to a steel key loop. This item will be made in China. 2) Stuffed miniature bunny key ring, item 4847 - which is comprised of a 4" long bunny with limbs which are "movable". The bunny is attached to a metal clip. This item will be made in South Korea.

Your samples are considered composite goods, consisting of different materials or made up of different components. Each item shall be classified as if it consisted of the material or component which gives it its essential character. For the teddy bear key chain, the steel key loop imparts the essential character. For the bunny key ring, the bunny imparts the essential character.

The applicable subheading for the teddy bear key chain will be 7326.20.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel wire, other. The duty rate will be 4.6% ad valorem.

The applicable subheading for the bunny key ring will be 9503.49.0020, HTS, which provides for toys representing animals or non-human creatures: other. The duty rate 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 this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division