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NY 888390

July 26, 1993

CLA-2-:91:S:N:N8:344 888390


TARIFF NO.: 9103.10.40

Ms. Lorraine M. Dugan
Associated Merchandising Corporation
1440 Broadway
New York, N. Y. 10018

RE: The tariff classification of a table clock from China.

Dear Ms. Dugan:

In your letter of July 14, 1993, you requested a tariff classification ruling on a table clock.

The submitted sample, style BA-6 by Classe, is a miniature battery operated quartz analog table clock with two non-working decorative alarm bells, a handle and two "feet." The clock, which has a watch movement, is in a metal gold tone case.

The applicable subheading for the miniature table clock with a watch movement and without an alarm 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: Battery powered: Other: Having no jewels or only one jewel in the movement. The rate of duty will be 36 cents each plus 6.9% on the case plus 5.3% on the battery.

You have asked that we provide you with guidance as to the country of origin marking requirements for this clock.

For purposes of 19 U.S.C. 1304, the country of origin of a clock is the same as the country of origin of its movement and the country of origin of a clock movement is that country where the movement parts have been assembled--substantially transformed-- from a collection of parts into the completed movement. We note that the BA-6 clock's watch movement is marked Japan. Therefore the country of origin of this clock is not China as indicated in your letter but Japan.

This marking may be placed on the face of the dial or on the outside surface of the back cover of the clock case. An adhesive sticker may be used for the section 304 marking so long as the sticker is affixed so securely that unless deliberately removed it will remain on the clock while it is in storage or on display and until delivered to the ultimate purchaser. This marking is intended to enable the ultimate purchaser to make an informed purchase decision based on the country of origin.

In addition to the country of origin marking regulations contained in 19 U.S.C. 1304, clocks are required to be marked in accordance with the special marking requirements specified in chapter 91, U.S. note 4, HTS. These markings are to be conspicuously and indelibly made by cutting, die-sinking, engraving, stamping or mold-marking (either indented or raised).

The special marking requirements are as follows:

(a) Watch movements shall be marked on one or more of the bridges or top plates to show:

(i) the name of the country of manufacture (ii) the name of the manufacturer or purchaser; and (iii) in words, the number of jewels, if any, serving a mechanical purpose as frictional bearings.

(d) Clock cases provided for in this chapter shall be marked on the most visible part of the outside of the back to show the name of the country of manufacture.

Your sample is being returned as requested.

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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