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NY 896772



April 21, 1994

CLA-2-91:S:N:N8:344 896772

CATEGORY: CLASSIFICATION

TARIFF NO.: 9103.10.20

Mr. Bret K. Donnelly
Sounds Fun
31250 Cedarvalley Drive
Westlake Village, CA 91362

RE: The tariff classification of a Mickey Mouse watch display from Hong Kong.

Dear Mr. Donnelly:

In your letter of April 5, 1994, you requested a tariff classification ruling on a Mickey Mouse watch display

The submitted sample is Model #POP-20 which is a point-of- purchase display incorporating the Mickey Mouse Talking Time Watch with a plastic base and clear protective shell. The watch is modified to use a pair of larger, easier-to-hear speakers mounted in the base, and to use larger batteries for longer life (also base-mounted). The modification to the watch is permanent, rendering the watch incapable of being worn on the wrist. A steel wire leash is attached to the bottom to allow the display to be secured to a counter-top to discourage theft. The bottom of the display has suction cups at each corner. A small rod is included with each unit to facilitate setting the watch's time through a hole in the clear shell. Depending on the character being imported, the model number will adjust (i.e., POP-21 with English speaking Mickey Mouse, POP-21FF with French speaking Mickey Mouse, POP-26 with Fred Flintstone). The only change to the display will be the coloring of the labels and copy.

The Mickey Mouse watch has an opto-electronic quartz movement in a plastic case with a plastic or rubber strap. A three dimensional plastic head of Mickey is situated just above the digital display. A synthesized voice announces the time when Mickey's hands, which extend around the sides of the case, are pressed.

The applicable subheading for the Model #POP-20, point of purchase display, will be 9103.10.20, Harmonized Tariff Schedule of United States (HTS), which provides for Clocks with watch movements, excluding clocks of heading 9104: Battery powered: with opto-electronic display only. The rate of duty will be 3.9% on the movement and case plus 5.3% on the battery.

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

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