CLA-2-91:RR:NC:MM:114 L83373
TARIFF NOS.: 9102.11.25, 9102.91.40, 9102.12.80, 9102.12.40, 9103.10.40
Ms. Lisa Ragan
Lisa Ragan Customs Brokerage
650 Atlanta South Pkwy.
Ste 500-A
College park, GA 30349
RE: The tariff classification of analog wrist watches, clip-on watches, opto-electronic wrist watches, and clocks with watch movements from China
Dear Ms. Regan:
In your letter dated March 15, 2005, on behalf of 37 Elephants Marketing LLC, you requested a tariff classification ruling.
The analog wrist watch has a battery operated quartz movement with no jewels, an alloy watch case (not silver plated), a yellow “happy face” dial, and hour, minute and sweep hands. The watch has a textile watch band with a hook and loop fastener. There is no model number indicated.
The item referred to as the Snow Keychain is an analog watch with a watch case in the shape of a snowflake, which is attached to a swivel link and a snap hook. The dial has a snowflake design outlined on the dial, and hour, minute and sweep hands. The watch is intended to be for hooked onto a backpack, a belt loop, a handbag, etc. It is battery operated and the movement contains no jewels.
The opto-electronic wrist watch is referred to as the Classic Digital Watch. It features hour, minute, second and day of the week display, month and date display, chronograph 1/100 sec. with lap/split control, four-year calendar, and an alarm function. The watch is battery operated, water resistant to 30 meters and has an EL backlight. The watch band is made of plastic.
The analog clock, referred to as the Banana Tree, is a clock with a battery operated quartz watch movement that contains no jewels. It has hour, minute and sweep hands and is part of the Breeze Collection. It is designed to stand on a desk or table.
The applicable subheading for the analog watch with textile watch band will be 9102.11.25, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, pocket watches and other watches, including stop watches, other than those of heading 9101: wrist watches, electrically operated, whether or not incorporating a stop watch facility: with mechanical display only: having no jewels or one jewel in the movement: with strap, band or bracelet of textile material or of base metal, whether or not gold- or silver-plated: other. The rate of duty will be 40 cents each plus 8.5 percent on the case plus 14 percent on the strap, band or bracelet plus 5.3 percent on the battery.
The applicable subheading for the Snowflake clip-on watch, will be 9102.91.40, Harmonized Tariff Schedule of the United States (HTS), which provides for other watches: other, electrically operated, having no jewels or only one jewel in the movement. The rate of duty will be 40 cents each plus 6 percent on the case plus 5.3 percent on the battery.
The applicable subheading for the opto-electronic watch will be 9102.12.80, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, electrically operated, whether or not incorporating a stop watch facility: with opto-electronic display only: other. The rate of duty will be free. The applicable subheading for the watch band for the opto-electronic watch will be 9102.12.40, Harmonized Tariff Schedule of the United States (HTS), which provides for straps, bands or bracelets entered with watches of subheading 9102.12.80 and classifiable therewith pursuant to additional U.S. note 2 to this chapter; all the foregoing whether or not attached to such watches at the time of entry: other. The rate of duty will be free.
The applicable subheading for the Banana Tree clock with a watch movement will be 9103.10.40, Harmonized Tariff Schedule of the United States (HTS), which provides for clocks with watch movements, excluding clocks of heading 9104: electrically operated: other: having no jewels or only one jewel in the movement. The rate of duty will be 24 cents each plus 4.5 percent on the case plus 3.5 percent on the battery.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Barbara Kiefer at 646-733-3019.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division