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NY G82586

October 19, 2000

CLA-2-91:RR:NC:MM:114 G82586


TARIFF NO.: 9102.12.80; 9102.12.40

Ms. Barbara Wierbicki
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of talking digital wrist watch from China

Dear Ms. Wierbicki:

In your letter dated September 29, 2000, on behalf of Avon Products, Inc., you requested a tariff classification ruling. A sample of the talking digital wrist watch was submitted with the ruling request.

The submitted watch, item number PP 217600, is identified as Watch N Learn. You have indicated in your letter that Watch N Learn is the former name for this item. The actual imported watches will be called Teach N Learn. The item is a wrist watch containing a battery-operated electronic watch movement with a liquid crystal display (LCD) in a plastic case with a plastic strap. On the front of the case are three buttons. Depressing the button situated beneath the LCD causes the screen to display the current time in analog and digital fashion. Depressing this button also activates a voice to tell the time and an activity appropriate for that time of day. A picture of the activity is displayed on the LCD that represents the activity described. Depressing the two buttons on either side of the LCD activates a display of a letter from the alphabet and then a pictorial representation of an object that starts with the displayed letter. At the same time a voice tells what the letter is, what the picture displayed is, gives off an appropriate corresponding sound and informs the listener that the name of the object starts with that letter. The submitted sample has the name Watch N Learn printed above the display. The imported watches will have the name Teach N Learn printed above the display. You have indicated that Avon Products, Inc., contemplates importing from China.

Your sample is being returned as requested.

The applicable subheading for the talking digital wrist watch will be 9102.12.80, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, pocket watches and other watches, including stop watches, other than those of heading 9101; wrist watches, electrically operated, whether or not incorporating a stop watch facility; with opto-electronic display only; other. The rate of duty will be free.

The applicable subheading for the plastic watch strap will be 9102.12.40, Harmonized Tariff Schedule of the United States (HTS), which provides for straps, bands or bracelets entered with watches of subheading 9102.12.80 and classifiable therewith pursuant to additional U.S. note 2 to this chapter; all the foregoing whether or not attached to such watches at the time of entry; other. The rate of duty will be free.

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 212-637-7058.


Robert B. Swierupski

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