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NY L81773




January 24, 2005

CLA-2-91: RR:NC:MM:114 L81773

CATEGORY: CLASSIFICATION

TARIFF NO.: 9105.21.80

Ms. Francine Marcoux
Hampton Direct, Inc.
350 Pioneer Drive
P.O. Box 1199
Williston, VT 05495

RE: The tariff classification of the Suction Cup Clock from China

Dear Ms. Marcoux:

This is in response to your letter dated December 23, 2004, requesting a tariff classification ruling on the Suction Cup Clock from China. A picture of the clock was submitted with the ruling request.

Item number 28700 for which you are requesting a ruling is identified as the Suction Cup Clock. The clock contains a quartz analog battery powered clock movement. The Suction Cup Clock measures approximately 6 inches in length, 6 inches in width and 1¾ inches in height. The clock is housed in a clear PVC and polypropylene case. The clock has a suction cup molded on the back used to fasten the item to tile, glass and other non-porous surfaces. The clock requires one AA battery to operate. The battery is not included.

The face of the Suction Cup Clock features the traditional Arabic numbers 1 through 12 around the periphery corresponding to the hours of the day. The clock has a round white dial with black hour and minute hands, and a red second hand.

The applicable subheading for the Suction Cup Clock will be 9105.21.80, Harmonized Tariff Schedule of the United States (HTS), which provides for wall clocks; electrically operated; other. The rate of duty will be 30 cents each plus 6.9 percent ad valorem on the case plus 5.3 percent ad valorem on the battery.

This ruling is being issued under provision of Part 177 of the Customs Regulations (19 CFR Part 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,

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