The tariff classification of a children’s projection wristwatch from China

N360074 April 7, 2026 CLA-2-91:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 9102.12.4000; 9102.12.8000 Cheryl Wynn Dollar General Corp 100 Mission Ridge Goodlettsville, TN 37072 RE: The tariff classification of a children’s projection wristwatch from China Dear Ms. Wynn: In your letter dated March 26, 2026, you requested a tariff classification ruling. A representative sample in a different design was provided and is being retained by this office. SKU # 44381401, described as a Christmas Projection Watch, is a children's battery-operated electronic projection wristwatch, marketed for ages 3 and older. The watch sample has a large flip cover in the shape of a giraffe’s head. You indicate the actual item will have a flip cover depicting Santa’s head or Gingerbread Man. The watch is constructed from polypropylene with a PVC watch strap. When the cover is flipped open, it reveals a digital display of date and time. The watch also includes two side buttons: one for projection and image-changing; and a rotatable knob for adjusting the focus of the projected image. You request classification under heading 9503, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tricycles, scooters, pedal cars, and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof….” toys. We disagree with your proposed classification. Watches providing the utilitarian purpose of telling time, are not classifiable in HTSUS Chapter 95 as toys. The applicable subheading for the watch will be 9102.12.8000, HTSUS, which provides for wrist watches, electrically operated, whether or not incorporating a stop watch facility, with opto-electronic display only. The rate of duty will be free. The applicable subheading for the wristwatch strap will be 9102.12.4000, HTSUS, which provides for straps, bands or bracelets entered with watches of subheading 9102.12.80 and classifiable therewith pursuant to additional U.S. note 2 to this chapter; all the foregoing whether or not attached to such watches at the time of entry: other. The rate of duty will be free. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Rosemarie Hayward at rosemariecasey.hayward@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division