CLA-2-:91:S:N:N8:344 886573

Mr. Bret K. Donnelly
Sounds Fun
31250 Cedarvalley Drive
Westlake Village, CA 91362

RE: The tariff classification of a Mickey Mouse watch display from Hong Kong.

Dear Mr. Donnelly:

In your letter of May 20, 1993, you requested a tariff classification ruling on a Mickey Mouse watch display. The submitted sample is Model #POP-01 which is a point-of- purchase display incorporating the Mickey Mouse Talking Time Watch (TW-01) with a plastic base. The Mickey Mouse watch has an opto- electronic quartz movement in a plastic case with a plastic or rubber strap. A three dimensional plastic head of Mickey is situated just above the display. A synthesized voice announces the time when Mickey's hands, which extend around the sides of the case, are pressed. The watch is modified to use a larger, easier- to-hear speaker mounted in the plastic base and larger batteries for longer life (also base-mounted). The modification to the watch is permanent, rendering the watch incapable of being worn on the wrist. A cardboard cutout of Mickey Mouse with the words "Mickey Talks" is inserted into the plastic base for the purpose of attracting consumer interest. An anti-theft steel wire leash is attached to the inside of the display for securing to a counter- top.

The applicable subheading for the Model #POP-01, point of purchase display, will be 9103.10.20, Harmonized Tariff Schedule of the United States (HTS), which provides for Clocks with watch movements, excluding clocks of heading 9104: Battery powered: with opto-electronic display only. The rate of duty will be 3.9% on the movement and case plus 5.3% on the 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