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NY L84291





May 9, 2005

CLA-2-85:RR:NC:1:110 L84291

CATEGORY: CLASSIFICATION

TARIFF NO.: 8537.10.9060

Ms. Stephanie De Silva
Avon Products, Inc.
1251 Avenue of the Americas
New York, NY 10020

RE: The tariff classification of a remote control watch from China.

Dear Ms. De Silva:

In your letter dated April 18, 2005 you requested a tariff classification ruling.

The merchandise under consideration is the Sharp Universal Remote Control Watch, reference PP 294106. A sample of the watch was submitted with your ruling request and will be returned to you.

The merchandise under consideration is a digital wristwatch. The Sharp Universal Remote Control Watch is a battery operated digital watch with remote control functions for TVs (Television), VCRs (Video Cassette Recorder), DVDs (Digital Videodisc), SATs (Satellite TV) and VCD (Video Compact Disc) products. The watch functions consist of timekeeping, stopwatch, day/date and alarm. This watch is also water resistant. The Sharp Universal Remote Control Watch includes an infrared control that is compatible with and can be programmed to operate with a variety of entertainment devices from major manufacturers. The remote control watch is classifiable under two heading, remote control devices under heading 8537 and wristwatches under heading 9102.

The General Rules of Interpretation (GRIs) of the Harmonized Tariff System (HTS) governs the classification of goods. GRI 3(b) provides, in relevant part, that composite goods, which cannot be classified by reference to 3(a), shall be classified as if they consisted of the material or component which gives them their essential character. The Sharp Universal Remote Control Watch meets the definition of a composite good under GRI 3(b), the remote control component provides the essential character.

The applicable subheading for the Sharp Universal Remote Control Watch will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricityFor a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 percent ad valorem.

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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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