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NY A84167

June 5, 1996

MAR-2-RR:NC:TP:344 A84167


Mr. Carl Baessler
Carl Baessler, Ltd.
2104 Stonington Ave.
Hoffman Estates, IL 60195

RE: The marking requirements for clocks.

Dear Mr. Baessler:

In your letter dated May 24, 1996, you requested a ruling on the marking for clocks.

Section 134.43(b), Customs Regulations (19 CFR 134.43 (b)), in conjunction with section 11.9 Customs Regulations (19 CFR 11.9) provides that watches and clocks must be marked in accordance with Chapter 91, U.S. Note 4 of the Harmonized Tariff Schedule of the United States (HTSUS), which states, in part,:

4. Special Marking Requirements: With the following exceptions, any movement or case provided for in this chapter, whether imported separately or attached to an article provided for in this chapter, shall not be permitted to be entered unless conspicuously and indelibly marked by cutting, die-sinking, engraving, stamping or mold-marking (either indented or raised), as specified below. Movements with opto-electronic display only and cases designed for use therewith, whether entered as separate articles or as components of assembled watches or clocks, are excepted from the marking requirements set forth in this note. The special marking requirements for clocks and watches are, in part, as follows:

(c) Clock movements shall be marked on the most visible part of the front or back plate to show: (i) the name of the country of manufacture; and (ii) the name of the manufacturer or purchaser.

(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.

You have submitted two samples of clocks with watch movements and have asked whether stamping the back of the case is an acceptable form of marking. Neither clock case is currently marked. The clock with collapsible stand is marked "Japan Movt"on the dial. The "floating" clock does not contain any marking. Marking with the country of origin of the movement is required. Case marking with permanent indelible ink on the stainless steel backs of both clocks would be allowable.

This ruling is being issued under the provisions of Section 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 Stanley Schwartz at 212-466-5895.


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