N329889

N329889 January 4, 2023 CLA-2-91:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 9105.91.80 Ms. Kathleen A. Howden Barinco International Corporation 5777 West Century Blvd. Los Angeles, CA 90045 RE: The tariff classification of a clock table from Italy or Colombia Dear Ms. Howden: In your letter dated December 16, 2022, you requested a tariff classification ruling on behalf of your client, Corum USA. A product leaflet, specifications, and photographs of the clock table were provided for our review. The article under consideration is identified as the Corum Golden Bridge Table Clock and is described as “a handmade table clock that is a one of a kind product made by an artist by order only.” The subject clock table is an analog clock with a movement that is powered by a 12 volt direct current (DC) 15,000 mAh (Milli Ampere Hour) rechargeable battery that will last for 6 days or approximately 144 hours. The movement weighs approximately 15 kilograms (kg) and is made up of a total of 295 parts, 156 components and 25 sub-assemblies that are manufactured in the United Kingdom. The clock is housed in the center of the table which serves as the clock case. The table/clock case is comprised of stainless steel, aluminum, glass, iron and acrylic. The table is in the shape of a wrist watch with two legs in the shape of bent watch straps/bands. The Golden Bridge Table Clock features a clear glass table top that protects the movement and allows one to see the workings of the movement. The clock case measures 124 centimeters (cm) in length by 66 cm in width by 63.2 cm in height and weighs approximately 66.4 kg. You stated that “The minute/hour hands are controlled via a precision stepper motor, with 3200 micro steps per revolution then through an in-house designed and manufactured precision gearbox which features a 108 tooth anti-backlash gear to minimize noise and improve the timekeeping accuracy. The balance and escapement are uniquely impulse via the carriage and a separate DC motor.” Both motors are controlled by a microprocessor which features feedback via a real time clock to ensure long term accuracy. By pulling a manual hand setting crown hidden inside the watch case crown, the hands can be adjusted clockwise or anti-clockwise via a contrate pinion and wheel arrangement. All the materials are high grade brass, stainless steel, and aircraft grade aluminum. The applicable subheading for the Corum Golden Bridge Table Clock will be 9105.91.80, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other clocks: other: 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. Articles classifiable under subheading 9105.91.80, HTSUS, which are products of Colombia may be entitled to duty free treatment under the United States-Colombia Trade Promotion Agreement (CTPA) upon compliance with all applicable regulations. The CTPA, however, is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on CTPA, check our website at www.cbp.gov and search for the term "CTPA". 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/current. 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 Ann Taub at Ann.Taub@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division