Quartz analog wrist watches

HQ 086562 JUNE 12, 1990 CLA-2 CO:R:C:G 086562 RFC CATEGORY: Classification TARIFF NO.: 9102.11.45 Mr. Adam C. Morrison Adamo Imports 302 South County Road, Suite 103 Palm Beach, FL 33480 RE: Quartz analog wrist watches Dear Mr. Morrison: This ruling letter is in response to your request of February 12, 1990, on behalf of Adamo Imports, concerning the tariff classification under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) for quartz analog wrist watches. A sample was submitted for examination. FACTS: The submitted sample consists of a lady's battery powered, mechanical display (analog), quartz wrist watch. The watch has a non-precious metal and non-precious metal clad case, a plastic strap, and a numerically marked, rotatable bezel surrounding the crystal. The movement has no jewels. The watch appears to be for causal and recreational use. The watches are assembled in China with parts made in Hong Kong. ISSUE: What is the proper tariff classification under the HTSUSA of battery powered, mechanical display wrist watches having no jewels in the movement and not having cases of precious metal or of metal clad with precious metal? LAW AND ANALYSIS: Classification of merchandise under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1 states, in part, that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes...." Subheading 9102.11, HTSUSA, provides for, among other things, battery powered, mechanical display wrist watches having no jewels in the movement (and not having cases of precious metal or of metal clad with precious metal as wrist watches with cases of precious metal or of metal clad with precious metal are classified under heading 9101). In the instant case, the above- described goods fall squarely within the provisions of subheading 9102.11, HTSUSA, and should be classified under this subheading. HOLDING: The above-described goods are classified under subheading 9102.11.45, HTSUSA, which provides for wrist watches, battery powered, with mechanical display only, having no jewels or only one jewel in the movement, other, other. The dutiable rate is 40 cents each + 8.5% on the case + 2.8% on the strap, brand or bracelet + 5.3% on the battery. Pursuant to U.S. Statistical Note 1(a), HTSUSA, when calculating the duties on various watches, clocks, watch movements, and clock movements, the articles must be constructively separated into their component parts and each component separately valued. In the instant case, the individual components must be separately reported under as follows: Movement....9102.11.4510 Case........9102.11.4520 Strap.......9102.11.4530 Battery.....9102.11.4540 Please be advised that your request regarding country-of- origin marking requirements will be dealt with in a separate ruling letter. Sincerely, John Durant, Director Commercial Ruling Division