CLA-2-91:RR:NC:TP:344 A80571

Mr. David A. Eisen
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway
43rd Floor
New York, NY 10036-8901

RE: The tariff classification of a stopwatch with cord, pen and writing tablet from China and/or Taiwan.

Dear Mr. Eisen:

In your letter dated February 20, 1996, on behalf of Avon Products, Inc. you requested a tariff classification ruling.

The submitted sample, "Sports Timer"- PP 143814 is a stopwatch timer incorporating a miniature writing tablet and ball point pen. The watch contains a battery operated, solid state, electronic watch movement with a liquid crystal display (LCD) in a plastic case attached to a textile neck cord. The back of the plastic case opens to reveal the writing tablet. The ball point pen hangs from the textile neck cord.

Your sample is being returned as requested.

The applicable subheading for the stopwatch timer will be 9102.91.20, Harmonized Tariff Schedule of the United States (HTS), which provides for ... other watches, ..., other than those of heading 9101: ... : Other: Electrically operated: With opto-electronic display only. The rate of duty will be 3.9% on the movement and case and 5.3% on the battery. The value of the ball point pen, writing tablet and textile cord are to be included in the value of the case.

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 you have any questions regarding the ruling, contact National Import Specialist Stanley J. Schwartz at 212-466-5895.

Sincerely,

Roger J. Silvestri
Director
National Commodity
Specialist Division