CLA-2 CO:R:C:G 086562 RFC
Mr. Adam C. Morrison
Adamo Imports
302 South County Road, Suite 103
Palm Beach, FL 33480
RE: Quartz analog wrist watches
Dear Mr. Morrison:
This ruling letter is in response to your request of
February 12, 1990, on behalf of Adamo Imports, concerning the
tariff classification under the Harmonized Tariff Schedule of the
United States Annotated (HTSUSA) for quartz analog wrist watches.
A sample was submitted for examination.
FACTS:
The submitted sample consists of a lady's battery powered,
mechanical display (analog), quartz wrist watch. The watch has a
non-precious metal and non-precious metal clad case, a plastic
strap, and a numerically marked, rotatable bezel surrounding the
crystal. The movement has no jewels. The watch appears to be for
causal and recreational use.
The watches are assembled in China with parts made in Hong
Kong.
ISSUE:
What is the proper tariff classification under the HTSUSA of
battery powered, mechanical display wrist watches having no
jewels in the movement and not having cases of precious metal or
of metal clad with precious metal?
LAW AND ANALYSIS:
Classification of merchandise under the HTSUSA is governed
by the General Rules of Interpretation (GRI's). GRI 1 states, in
part, that "for legal purposes, classification shall be
determined according to the terms of the headings and any
relative section or chapter notes...."
Subheading 9102.11, HTSUSA, provides for, among other
things, battery powered, mechanical display wrist watches having
no jewels in the movement (and not having cases of precious metal
or of metal clad with precious metal as wrist watches with cases
of precious metal or of metal clad with precious metal are
classified under heading 9101). In the instant case, the above-
described goods fall squarely within the provisions of subheading
9102.11, HTSUSA, and should be classified under this subheading.
HOLDING:
The above-described goods are classified under subheading
9102.11.45, HTSUSA, which provides for wrist watches, battery
powered, with mechanical display only, having no jewels or only
one jewel in the movement, other, other. The dutiable rate is
40 cents each + 8.5% on the case + 2.8% on the strap, brand or
bracelet + 5.3% on the battery.
Pursuant to U.S. Statistical Note 1(a), HTSUSA, when
calculating the duties on various watches, clocks, watch
movements, and clock movements, the articles must be
constructively separated into their component parts and each
component separately valued. In the instant case, the individual
components must be separately reported under as follows:
Movement....9102.11.4510
Case........9102.11.4520
Strap.......9102.11.4530
Battery.....9102.11.4540
Please be advised that your request regarding country-of-
origin marking requirements will be dealt with in a separate
ruling letter.
Sincerely,
John Durant, Director
Commercial Ruling Division