CLA-2-91:RR:NC:MM:114 G84931

Ms. Maria Da Rocha
D & D Customhouse Brokerage
701 Newark Avenue
Suite LL1
Elizabeth, NJ 07208

RE: The tariff classification of analog pocket watch with display stand from China

Dear Ms. Da Rocha:

In your letter dated November 29, 2000, on behalf of Tristar Products, you requested a tariff classification ruling on an analog pocket watch with a display stand from China. A sample of the analog pocket watch with display stand was submitted with the ruling request.

The submitted sample is identified as a Liberty Pocket Watch. The Liberty Pocket Watch consists of an analog pocket watch with a display stand. The watch is a battery operated analog pocket watch in a round gold-plated zinc alloy case. The watch has no jewels in the movement. The face of the watch features the Roman numerals I through XII around the periphery corresponding to the hours of the day. The watch has a round white dial with black hour, minute and second hands. The Liberty Pocket Watch contains an authentic Eagle Silver Dollar with “Walking Liberty” image mounted with a swivel mechanism. Instructions indicate that to change the side of the coin seen on the face of the watch case, gently press the upper portion of the coin in and continue until the image is reversed. You indicate in your letter that the stand is composed of “poly-stone”. The essential character of this composite article is derived from the watch.

The applicable subheading for the analog pocket watch with display stand will be 9102.91.40, 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; other; electrically operated; other; having no jewels or only one jewel in the movement. The rate of duty will be 40 cents each plus 6 percent ad valorem on the case plus 5.3 percent ad valorem on the battery and remains unchanged in 2001.

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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division