HQ 089971

November 1, 1991

CLA-2 CO:R:C:T 089971 HP

CATEGORY: Classification

TARIFF NO.: 9504.90.9080

Mr. Ronald J. Seiden

Procedures Manager

Bucci Imports

West End Games

RD 3

Box 2345

Honesdale, PA 18431

RE: Fantasy role play games books are expansion modules are

designed to enhance fantasy game play, not for passive

reading. Books; printed matter.

Dear Mr. Seiden:

This is in further reply to your various correspondence

with Congressman McDade, with respect to your mail importation

of several role playing games. Please reference our case

number HQ 089835 of July 18, 1991. As we informed Congressman

McDade, we are now issuing you a binding ruling as to the

appropriate classification of these games, under the

Harmonized Tariff Schedule of the United States Annotated

(HTSUSA).

FACTS:

The merchandise at issue consists of expansion module

books which are game reference materials designed to expand

fantasy role play games. They provide maps and descriptive

narratives of fictional worlds, environmental scenarios,

character generation and development, and background

informational resources for use in fantasy role play games

such as Dungeons and Dragons. The books offer inspiration,

guidelines, games rules, and a fantasy world, promote personal

development in role play campaigns, and serve as a base from

which role playing can be extended.

ISSUE:

Whether the books are considered written materials of

Chapter 49, or games under Chapter 95, HTSUSA?

LAW AND ANALYSIS:

In HRL 085214 of November 24, 1989, we classified

substantially similar merchandise as follows:

Heading 9504, HTSUSA, covers articles

for arcade, table or parlor games...parts

and accessories thereof. The merchandise

in issue consists of materials that

complements and amplifies the fantasy game

play activity. The modules, however, are

also books as provided for in heading

4901. Since two headings describe the

subject merchandise, GRI 3 must be

consulted.

GRI 3(a) states that "(t)he heading

which provides the most specific

description of the article shall be

preferred over headings providing a more

general description." In our opinion,

heading 9504 provides a more specific

description of the merchandise at issue.

The modules enhance fantasy game play;

they were not designed for passive

reading.

We agree with the analysis set forth in HRL 085214, supra, and

adopt it for purposes of its application to the instant

merchandise.

HOLDING:

As a result of the foregoing, the instant merchandise is

classified under subheading 9504.90.9080, HTSUSA, as articles

for arcade, table or parlor games, including pinball machines,

bagatelle, billiards and special tables for casino games;

automatic bowling alley equipment; parts and accessories

thereof; other, other, other, other. The applicable rate of

duty is 4.64 percent ad valorem.

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,

John Durant, Director

Commercial Rulings Division