CLA-2-91:RR:NC:MM:114 D81907

Mr. Edward L. Hart, Jr.
V. Alexander & Co., Inc.
P.O. Box 30250
Memphis, Tennessee 38130-0250

RE: The tariff classification of an alarm clock with watch movement made in China

Dear Mr. Hart:

In your letter dated August 25, 1998, on behalf of The Sharper Image Corporation, you requested a tariff classification ruling.

The submitted item number MS181 is a battery operated analogue alarm clock with a watch movement. The small square clock is made of metal and incorporates a stop watch facility. The clock measures approximately 3.8 cm in width by 1.4 cm in length by 4.5 cm in height. The watch movement is approximately 33.5 mm in diameter and has a thickness of approximately 9.75 mm. There are no jewels in the movement.

The clock will be manufactured in China with the exception of the battery which will be made in Japan. The clock requires a Silver Oxide battery or equivalent battery to operate.

Your sample is being returned as requested.

The applicable subheading for the clock with watch movement (movement does not exceed 12 mm in thickness and 50 mm in width, length or diameter) will be 9103.10.40, Harmonized Tariff Schedule of the United States (HTS), which provides for clocks with watch movements, excluding clocks of heading 9104; electrically operated; other; having no jewels or only one jewel in the movement. The rate of duty will be 25 cents each plus 5 percent ad valorem on the case plus 3.9 percent ad valorem on the battery.

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 212-466-5685.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division