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NY L84130





April 28, 2005

CLA-2-91:RR:NC:MM:114 L84130

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.12.80; 9102.12.40

Ms. Stephanie De Silva
Import/Export Analyst
Avon Products, Inc.
1251 Avenue of the Americas
New York, NY 10020

RE: The tariff classification of the Digital Watch and Mini Remote Control Car

Dear Ms. De Silva:

In your letter dated April 13, 2005, you requested a tariff classification ruling on the Digital Watch and Mini Remote Control Car. A sample of the Digital Watch and Mini Remote Control Car was submitted with the ruling request.

The submitted item number PP293619 is identified as the Digital Watch and Mini Remote Control Car. The combination article consists of a digital wrist watch and a mini remote control car. The wrist watch has a black plastic band, and a black and silver plastic watch case. The watch contains a battery-operated electronic watch movement with a liquid crystal display (LCD) that features the time and date. The watch also acts as a remote control device for the mini car. You have stated in your letter that the watch movement is made in Japan and the watch is assembled in China. The instruction sheet informs the user to turn the car on using the on/off switch on the bottom of car. The user is advised to make sure that nothing is blocking the infrared sensor on the car and that the transmitter of the watch is directed toward the car. The Digital Watch and Mini Remote Control Car requires two XAG13 batteries to operate. The batteries are included. The Digital Watch and Mini Remote Control Car will be packaged in a cardboard display box ready for retail sale. The essential character of this composite article is derived from the digital watch.

The applicable subheading for the Digital Watch and Mini Remote Control Car 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, 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.

Your sample is being returned as requested.

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 646-733-3019.

Sincerely,

Robert B. Swierupski
Director,

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