CLA-2-:91:S:N:N3G:344 863664

Mr. Solomon Weber
All-Ways Forwarding Co., Inc.
Port Elizabeth Plaza
1201 Corbin Street
Elizabeth, NJ 07201

RE: The tariff classification of a wall clock from Belgium.

Dear Mr. Weber:

In your letter of May 22, 1991, on behalf of E.T. Table Art Ltd., you asked for a tariff classification ruling on a clock from Belgium.

The sample submitted with your letter is a quartz analog wall clock con-sisting of a Junghans (Germany) calibre W738 clock movement containing no (0) jewels, with a molded plaster dial. The clock movement is 58mm in width and the clock dial is 13.8cm x 19cm.

The plaster dial, made in Belgium, has Roman numerals at the III, VI, IX and XII o'clock positions and indices at the 1, 2, 4, 5, 7, 8, 10 and 11 o'clock positions. Molded into the dial, below the numerals and indices, is a scene depicting a black wrought iron gate between two red brick columns and green shrubbery.

The dial and movement are assembled together in Belgium. A steel wire loop is affixed to the top of the movement and it is used to hang the clock on a wall.

A clock dial is a part of a clock movement. The molded plaster dial, including the depiction of wrought iron gate, brick wall and shrubbery, is a part of (an entirety with) the Junghans clock movement. The sample clock is therefore a wall clock without a clock case. The applicable subheading for the quartz analog wall clock will be 9105.21.80, Harmonized Tariff Schedule of the United States (HTS), which provides for other clocks: wall clocks: battery or AC powered: other. The rate of duty will be 30 cents each plus 6.9% on the case plus 5.3% on the battery. Because the clock has no clock case the 6.9% portion of the compound rate of duty is inapplicable. Nor will the 5.3% on the battery apply if the clock is imported without a battery. 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