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HQ 957069

December 14, 1994

CLA-2 CO:R:C:M 957069 MMC


TARIFF NO.: 9114.40.40

Mr. Louis Piropato
W.A. Phelps & Co., Inc.
Suite 2109
One World Trade Center
New York, New York 10048

RE: Plates for a clock movement; En 91.14

Dear Mr. Piropato:

This is in response to your letter dated August 31, 1994, on behalf of Sunbeam Precision Measurement, requesting a binding ruling concerning the classification under the Harmonized Tariff Schedule of the United States (HTSUS), of a set of plates for a clock movement. A sample of the plates and their corresponding movement were submitted for our review.


The set of plastic plates consists of a back pillar plate, designated as P/N 150260 and a front top plate designated as P/N 150252. After importation, the plates are incorporated into a clock movement for a Sunbeam 60-minute bell timer (model # 8153).


What is the proper classification of the set of plates?


Classification of merchandise under the HTSUS is in accordance with the General Rules of Interpretation (GRI's). GRI 1, HTSUS, states, in pertinent part, that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes. Chapter 91, HTSUS, provides for clocks and watches and parts thereof.

Heading 9114, HTSUS, provides for other clock or watch parts. In understanding the language of the HTSUS, the Harmonized Commodity Description and Coding System Explanatory Notes (Ens) may be consulted. The Ens, although not dispositive nor legally binding, provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128, (August 23, 1989).

En 91.14, HTSUS, p.1552 and 1553, states in pertinent part, that:
the principal clock or watch parts classified here are:

(regardless of complexity of system)

...(9) Platform escapements consist of the plate, bridges, escapement, balance-wheel and hairspring, and the regulator of a clock or watch movement, with or without train. They remain classified here whether assembled with the escapement regulated, or unassembled.


Many of the parts of these movements are similar in principle to parts of watch movements but are larger.

The present articles are plates suitable for assembling on a clock movement. Therefore they are classifiable under subheading 9114.40.40, HTSUS, which provides for plates and bridges: any plate, or set of plates suitable for assembling thereon a clock movement.


The plastic plates suitable for assembling on a clock movement are classifiable under subheading 9114.40.40, HTSUS, with a column one rate of duty of $0.15 each.


John Durant, Director

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