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NY 851582

April 27, 1990

CLA-2-91:S:N:N:3G:344 851582


TARIFF NO.: 9102.91.2000

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.


Jean F. Maguire
Area Director

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