CLA-2-91:S:N:N:3G:344 851582
Mr. W. C. McGehee
House of Lloyd, Inc.
11901 Grandview Road
Grandview, MO 64030
RE: The tariff classification of an LCD watch/pouch/key
ring/swivel snap hook from Hong Kong.
Dear Mr. McGehee:
In your letter of April 3, 1990, you requested a tariff
classification ruling on an LCD watch/pouch/key ring/swivel snap
hook.
The submitted sample, your item number 170347, is a battery-
operated solid-state LCD electronic watch movement mounted on the
front of a textile pouch. The pouch, a mini-backpack, measures
3" x 3" x 1 1/2" wide, with a zippered closure. Attached to a
loop on the back of the pouch is a stainless steel split ring and
a plastic swivel snap hook.
The sample watch/pouch/key ring/swivel snap hook is a
composite article that prima facie appears to be classifiable
under four headings--3926, 4202, 7326 and 9102. In keeping with
General Rule of Interpretation (GRI) 3(a), because the four
headings each refer to part only of the composite article, the
four headings are regarded as equally specific in relation to the
article.
GRI 3(b) requires that composite goods consisting of
different materials or made up of different components, which
cannot be classified by reference to GRI 3(a), shall be
classified as if they consisted of the material or component
which gives them their essential character, insofar as this
criterion is applicable. We have concluded that the LCD watch,
the nylon pouch, the split key ring and the swivel snap hook are
equally essential components of the sample and neither watch nor
pouch nor key ring nor swivel snap hook imparts an essential
character to the composite article. Therefore, the article is
not classifiable by reference to GRI 3(b).
GRI 3(c) states: "When goods cannot be classified by
reference to 3(a) or 3(b), they shall be classified under the
heading which occurs last in numerical order among those which
equally merit consideration." Accordingly, the applicable HTS
subheading for the LCD watch/pouch/key ring/swivel snap hook,
item number 170347, will be 9102.91.2000, which provides for
other watches...battery-powered: with opto-electronic display
only. The duty rate will be 3.9 percent on the watch movement,
pouch, key ring and swivel snap hook, plus 5.3 percent on the
battery.
The textile pouch, as a part of a composite article
classifiable in subheading 9102.91.2000, HTS, is not subject to
any quota or visa requirements.
This ruling is being issued under the provisions of Section
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,
Jean F. Maguire
Area Director
New York Seaport