The tariff classification of The Clocket Pocketbook

NY L81325 January 11, 2005 CLA-2-91:RR:NC:MM:114 L81325 CATEGORY: Classification TARIFF NOS.: 9105.21.80 ;4202.22.1500 Ms. Edith Tolchin EGT Global Trading P.O. Box 231 Florida, NY 10921 RE: The tariff classification of The Clocket Pocketbook Dear Ms. Tolchin: In your letter dated December 14, 2004 you requested a tariff classification ruling. The Clocket Pocketbook is a handbag with a clock. The handbag is made of imitation leather consisting of a fabric backed sheeting of plastic. The sheeting of plastic will be the exterior surface constituent material and will alternatively simulate a top grain or a patent leather. The handbag may be manufactured in China, Taiwan or Hong Kong from raw material that are products of other countries. The analog wall clock has a battery operated quartz movement. The clock is in a zippered compartment of the handbag and can be readily removed from the handbag. The clock may be manufactured in China, Taiwan or Hong Kong from raw materials from other countries. Regarding the country of origin marking of the handbag and the clock under section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), we cannot rule on the country of origin marking of the handbag without specific information regarding the country of manufacture of the handbag. Also, we cannot issue a ruling on the country of origin marking of the clock without specific information regarding the country of manufacture of the clock’s movement. In addition to the country of origin marking requirements of section 304, Tariff Act of 1930, as amended, there are special marking requirements for clocks. We are attaching a copy of Additional U.S. Note 4 of chapter 91 of the Harmonized Tariff Schedule of the United States (2005), which explains the special marking requirements. Please note that Additional U.S. Note 4 (b) details the special marking requirements for clock movements and Additional U.S. Note 4 (d) details the special marking requirements for clock cases. The applicable subheading for the wall 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 on the case plus 5.3 on the battery. The applicable subheading for the handbag will be 4202.22.1500, Harmonized Tariff Schedule of the United States (HTS), which provides, in part, for handbags, of a sheeting of plastic with outer surface of sheeting of plastic or of textile materials, with outer surface of sheeting of plastic. The rate of duty will be 16 percent ad valorem. Goods classified within tariff number 4202.22.1500, HTS, are not currently subject to quota or visa restrictions. The sample of the Clocket Pocketbook is being returned to you as requested. 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 Barbara Kiefer at 646-733-3019. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division