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NY B86822

JULY 15, 1997

CLA-2-91:SV:S:C:B16 B86822

Tariff No.: 9103.10.2030 & 9103.10.2040

Mr. Alan Drake
Fritz Companies, Inc.
1721 West Elfindale, Suite 205
Springfield, MO 65807

Subject: Classification of "ReCORD'G" Talking Picture Frame/Clock

Dear Mr. Drake:

In your letter dated June 19, 1997, you requested a binding tariff classification ruling for the "ReCORD'G Talking Picture Frame/Clock" on behalf of your client, R. D. Manufacturing Corporation.

The "ReCORD'G" talking picture frame/clock is a 2.55" X 2.5" X 0.58" device which records a 10 second message and allows playback. The device also contains a picture frame and digital clock which displays time and date. Four AG13 batteries are required for operation. The country of origin is Switzerland.

The "ReCORD'G" talking picture frame/clock is a composite article which incorporates a recorder, clock and picture frame. In this case the essential character cannot be determined. Therefore, according to GRI-3(c), the classification occurring last in numerical order appears to be applicable.

The applicable classifications for the "ReCORD'G" talking picture frame/clock is 9103.10.20 of the Harmonized Tariff Schedule (HTS) of the United States, which provides for "Clocks with watch

Movements: Electrically operated: With opto-electronic display only. The statistical suffix for the movement and case is 30 and the statistical suffix for the battery is 40. The applicable rate of duty is 3.1% on the movement and case plus 4.3% on the battery.

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 upon each importation of this merchandise. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.



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