HQ 083082: "Needlework Box"

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                         HQ 083082
                      March 20, 1990

CLA-2 CO:R:C:G  083082 SLR

CATEGORY: Classification

TARIFF NO.: 9503.70.8000

Steven M. Schneebaum, Esq.
Patton, Boggs & Blow
2550 M Street, N.W.
Washington, D.C.  20037-1350

RE: "Needlework Box"

Dear Mr. Schneebaum:

     This ruling is in response to your request regarding the
proper classification of a needlework kit for children under the
Harmonized Tariff Schedule of the United States Annotated
(HTSUSA).  A sample produced in Hong Kong was forwarded for our
examination.

FACTS:

     The subject kit consists of various needlework articles
grouped into different activities and packed in separate
cellophane pouches.  The grouped contents of the kit are listed
as follows:

     (1) Plastic loom 6-1/4 inches by 8-1/2 inches;
         Circular embroidery plastic frame;
         Two spools of yarn;
         Five spools of embroidery thread;
         Set of two weaving needles, one embroidery needle, two
         knitting needles and one crochet hook, all of plastic;
         and
         A piece of nonwoven textile material with picture of a
         toy animal and flower.

     (2) Steel needle;
         Metal scissors;
         A piece of nonwoven textile material with picture of
         cartoon animal;
         Plastic frame 4-1/2 inches by 5-3/4 inches;
         Three spools of embroidery thread;
         Plastic thimble; and
         Aluminum needle threader.


                              -2-

     (3) A piece of nonwoven textile material with picture of a
         rag doll;
         Steel needle; and
         One spool of embroidery thread.

     (4) Plastic bobbin with pegs;
         Plastic needle;
         Crochet hook; and
         Four spools of yarn.

     (5) Circular plastic flower loom;
         Plastic crochet hook; and
         Two spools of yarn.

     (6) Perforated sewing cards;
         Plastic needle; and
         Four spools of embroidery thread.

     All of the articles are contained in a plastic molded
carrying case measuring 11 inches by 9 inches.

ISSUE:

     What is the proper classification of the needlework kit
under the HTSUSA?

LAW AND ANALYSIS:

     Subheading 9503.70, HTSUSA, provides for other toys, put up
in sets or outfits, and parts and accessories thereof.
According to Explanatory Note 95.03, educational toys, such as
sewing and knitting sets, fall within the purview of Heading
9503.

     The "Needlework Box" enters the U.S. neatly packaged, ready
for distribution to consumers.  Containing diverse components,
the kit, nonetheless, is devoted to needlework crafts.  The kit
is educational; children learn to weave, knit, and embroider.

HOLDING:

     The subject merchandise is classifiable in subheading
9503.70.8000, HTSUSA, which provides for other toys, put up in
sets or outfits, and parts and accessories thereof, other, other.
The rate of duty is 6.8 percent ad valorem.


                                Sincerely,


                                John Durant, Director
                                Commercial Rulings Division