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NY B87235

August 1, 1997

CLA-2-91:RR:NC:MM:114 B87235


TARIFF NO.: 9105.91.80

Ms. Tammy Locke
Wholesale Supply Company, Inc.
International Department
7100 Service Merchandise Drive
Brentwood, TN 37207

RE: The tariff classification of Anniversary Clocks from Japan

Dear Ms. Locke:

In your letter dated June 27, 1997 you requested a tariff classification ruling on a clock.

Model number 2169C-Faux Marble Anniversary Clock is a battery operated desk/table clock which does not have an alarm function. The clock has a rotary pendulum and a glass dome. There are two movements; one is for the timepiece, the other is used for the rotary pendulum.

The applicable subheading for the Anniversary Clock will be 9105.91.80, Harmonized Tariff Schedule of the United States (HTS), which provides for other clocks; other; electrically operated; other. The rate of duty will be 30 cents each plus 6.9 percent on the case plus 5.3 percent on the battery. The provision for duty of 30 cents each is the rate per clock, irrespective of the number of movements contained in the clock. You have inquired as to whether or not the pendulum of the Anniversary Clock should be included in the FOB value breakdown with the movement. The pendulum is not considered to be part of the clock movement. Additional U.S. Note 1 (d) states that "the clock movement is the device regulated by a balance wheel and hairspring, quartz crystal or any other system capable of determining intervals of time, with a display or a system to which a mechanical display can be incorporated."

This ruling is being issued under the provisions of Part 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 Barbara Kiefer at 212-466-5685.


Robert Swierupski
Chief, Metals and Machinery Branch

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