CLA-2-91:RR:NC:MM:114 M83986

Mr. Gregory S. McCue
Steptoe & Johnson LLP
1330 Connecticut Avenue, NW
Washington, DC 20036-1795

RE: The tariff classification of watch parts

Dear Mr. McCue:

In your letter dated May 24, 2006, on behalf of Citizen Watch Co., Ltd., you requested a tariff classification ruling.

The article for which you are requesting a ruling is a plate-spacer subassembly. Pictures and samples were submitted with your request.

In its imported condition, the subassembly will consist of three parts: a pillar plate, a minute wheel and pinion and a circuit spacer (spacer for setting stem). According to your letter, the parts are pressed together by a machine press at five points and cannot be disassembled without damage being caused to the subassembly. The plate-spacer subassembly will be used as a part of a movement for a wristwatch.

The applicable subheading for the plate-spacer subassembly will be 9114.90.1500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other clock or watch parts, other, assemblies and subassemblies for watch or clock movements consisting of two or more pieces or parts fastened or joined inseparably together, for watch movements. The rate of duty will be 7.2 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

Your samples are 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,
National Commodity
Specialist Division