CLA-2-:91:S:N:N3G:344 865684

Mrs. Crystal L. Osborne
Alfred H. Marzolf, Inc.
157 Yesler Way Suite 605
Seattle, WA 98104

RE: The tariff classification of a 60-minute timer made in China.

Dear Mrs. Osborne:

In your letter of July 29, 1991, on behalf of Sunbeam Leisure Products, Neosho, Missouri, you asked for a tariff classification ruling on a timer from China. The sample submitted with your inquiry is a 0-to-60 minute bell timer, in a 2 1/2 inch round metal case, without a dial and pointer knob, intended for use on Sunbeam barbecue grills. The timer has a no (0) jewel mechanical clock movement, that is regulated by a balance wheel and hairspring. The user selects the desired cooking time, in 1-minute increments, and a bell rings to announce the expiration of the preselected time period.

The Sunbeam timer is a process timer. Time switches differ from process timers in that instead of actuating a striking system at a given time, they "make" or "break" an electric circuit. The sample timer is not a time switch because it does not have a switch or a relay for the on-off control of electric circuits.

The applicable subheading for the Sunbeam BBQ grill timer will be 9106.90.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for time of day recording apparatus and apparatus for measuring, recording or otherwise indicating intervals of time, with clock or watch movement or with synchronous motor (for example, time registers, time- recorders). The rate of duty will be 45 cents each + 7% + 2 1/2 cents per jewel. [The movement in the sample timer has no (0) antifriction jewels]. 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 at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport