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NY L82883





March 23, 2005

CLA-2-91: RR:NC:MM:114 L82883

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 Mini Suction Cup Clock from China

Dear Ms. Marcoux:

This is in response to your letter dated March 9, 2005, requesting a tariff classification ruling on the Mini Suction Cup Clock from China. A picture of the clock was submitted with the ruling request.

Item number 29610 for which you are requesting a ruling is identified as the Mini Suction Cup Clock. The clock contains a quartz analog battery powered clock movement. The Suction Cup Clock measures approximately 3½ inches in length, 3½ inches in width and 1 inch in height. The clock is housed in a blue 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 button cell battery to operate. The battery is 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, minute and second hands.

The applicable subheading for the Mini 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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