Silent quartz analog wall clock, 12 inch, aluminum frame with glass lens
Country of origin for this scenario: China.
Recommended HTS code
9105.21.80
Other
MEDIUM confidence. Heading 9105.21.80 is clearly supported by multiple on-point CBP rulings classifying battery-operated quartz analog wall clocks at this subheading, and the HTS row confirms the description. Confidence is MEDIUM rather than HIGH because the 10-digit statistical suffix is not present in the supplied HTS rows (no .XX suffix visible for 9105.21.80), and the movement diameter (≤50 mm vs. >50 mm) has not been verified — if the movement measures ≤50 mm, the clock could fall under 9105.29 (non-electrically operated) subheadings; however, quartz battery-powered movements are treated as electrically operated so 9105.21 is correct. The 10-digit code cannot be confirmed from the supplied evidence.
Classification analysis generated on July 24, 2026 from the current Harmonized Tariff Schedule and published CBP rulings, for the product description shown — our analysis, not legal advice.
The question to put to a licensed broker
Please confirm the clock movement diameter (≤50 mm or >50 mm) and verify the current 10-digit statistical suffix for 9105.21.80 with CBP, and confirm whether any active Section 301 exclusion applies to this specific product under 9903.88.15 or a successor overlay.
How the classification was reached
GRI Reasoning
GRI 1 — Heading Determination
The product is a silent quartz analog wall clock with an aluminum frame and glass lens. Chapter 91 of the HTS covers clocks and clock parts. Heading 9105 covers "Other clocks," and its subheading structure distinguishes alarm clocks (9105.11/9105.19), wall clocks (9105.21/9105.29), and other clocks (9105.91/9105.99). The product is explicitly a wall clock, directing classification to 9105.21 (electrically operated) or 9105.29 (other).
GRI 1 — Subheading Selection: 9105.21 vs. 9105.29
A quartz analog clock is powered by a battery through an electronic oscillator circuit. CBP has consistently held that battery-operated quartz analog movements are "electrically operated" for tariff purposes. Rulings 895332, K83562, 810023, 870296, and 863664 all classify battery-operated quartz analog wall clocks under 9105.21.80. Therefore, 9105.21 (electrically operated) governs, not 9105.29.
GRI 1 — Further Subheading: 9105.21.40 vs. 9105.21.80
- 9105.21.40 covers wall clocks "with opto-electronic display only" — i.e., digital/LED/LCD displays. This product has an analog dial, so 9105.21.40 does not apply.
- 9105.21.80 covers "Other" electrically operated wall clocks — the residual provision capturing all battery/AC-powered wall clocks that are not opto-electronic display only. An analog quartz wall clock fits squarely here.
Ruling Precedent
All five supplied CBP rulings (895332, K83562, 810023, 870296, 863664) consistently classify battery-operated quartz analog wall clocks under 9105.21.80. Ruling K83562 is directly on-point: a quartz analog wall clock from China in a round case, battery-powered, classified at 9105.21.80.
Candidate Code Elimination
- 9105.11.40 / 9105.11.80: These are alarm clocks (9105.11), not wall clocks. The product is a wall clock. Eliminated.
- 9105.19.10: Falls under 9105.19 (non-electrically operated alarm clocks). Not applicable to a battery-powered quartz wall clock. Eliminated.
- 9105.21.10 (proposed in candidate analysis): This code does not appear in the supplied HTS rows; 9105.21 breaks only into 9105.21.40 and 9105.21.80 in the verified evidence. Not supported.
Duty Rate (General Column)
Per the verified HTS row for 9105.21.80: 30¢ each + 6.9% on the case + 5.3% on the battery
- Column 2 (other): 75¢ each + 45% on the case + 35% on the battery (not applicable — China is not a Column 2 country for this heading under normal circumstances, but Section 301 applies).
Section 301 / Chapter 99 Overlay
No footnote citing 9903.88.15 appears on the 9105.21.80 row in the supplied evidence (the 9903.88.15 footnotes appear on 9105.19.10, 9105.19.20, 9105.19.30, 9105.29.10, 9105.29.20, 9105.29.30, and 9105.29.50.00 rows, not on 9105.21.80). However, as a product of China, the importer must independently verify whether 9105.21.80 is listed in U.S. Note 20 annexes under any active Section 301 overlay (List 3 or List 4A at 9903.88.03/9903.88.04/9903.88.15) or whether a USTR exclusion applies. This is flagged as a verification question for the broker.
10-Digit Statistical Code
The supplied HTS rows for 9105.21.80 do not show a 10-digit suffix. The deepest code supported by the evidence is the 8-digit 9105.21.80.
Annual Duty Estimate (Illustrative)
- 7,000 units × $0.30 = $2,100 (per-unit component)
- Case value per unit (aluminum frame, estimated ~$1.50 of the $4.40 unit value): 7,000 × $1.50 × 6.9% ≈ $725
- Battery not imported with unit per standard practice — 5.3% component likely $0
- Base duty estimate: ~$2,825/year before any Section 301 overlay
Cited CBP rulings
Every ruling below was fetched from CBP’s public CROSS database and verified to exist before this page was published. Links go to the official ruling text.
What it classified: Quartz analog wall clock from China in a round plastic case, battery-powered, 8-inch diameter
Why it’s analogous: Directly on-point: same origin (China), same movement type (quartz analog, battery-powered), same clock type (wall clock). CBP classified it at 9105.21.80.
What it classified: Five battery-operated quartz analog wall clocks from Taiwan (round cases, pendulum and standard types)
Why it’s analogous: Establishes that battery-operated quartz analog wall clocks — regardless of case material or style — are classified at 9105.21.80 as electrically operated wall clocks.
What it classified: Battery-operated quartz analog wall clocks in plastic cases from Taiwan (items 4 and 5)
Why it’s analogous: Confirms 9105.21.80 for battery-operated quartz analog wall clocks; also distinguishes wall clocks (9105.21.80) from table/mantle clocks (9105.91.80).
What it classified: Battery-operated quartz analog wall clock (holstein cow fiberboard form) from Canada
Why it’s analogous: Confirms that any battery-operated quartz analog wall clock — regardless of case material — falls under 9105.21.80; illustrates how the 6.9%-on-case component applies only when a case is present.
What it classified: Quartz analog wall clock with Junghans movement (0 jewels, 58mm wide) and molded plaster dial, from Belgium
Why it’s analogous: Confirms 9105.21.80 for quartz analog wall clocks; movement width of 58mm (>50mm) is consistent with the present 12-inch wall clock, supporting 9105.21 over 9105.29 subheadings that require movement ≤50mm.
What the duty looks like
Duty math shown for illustrative declared values — $4.40 per unit at 7,000 units per year is our assumption for this explainer, not a measurement of anyone's imports. Your numbers will differ.
- Base duty rate (column 1, general)
- 30¢ each + 6.9% on the case + 5.3% on the battery
- Annual declared value at the illustrative numbers
- $30,800
Alternatives considered
The full candidate set from the fetched tariff rows — including rows that would carry a higher duty. Shown so the reasoning is checkable, not to offer a rate menu.
| Code | Description | General rate | Note |
|---|---|---|---|
| 9105.29.40.00 | Valued not over $5 each | 15¢ each + 6.4% | Covers non-electrically operated wall clocks valued not over $5 each (rate: 15¢ each + 6.4%; general column). At $4.40 declared value this unit would qualify for the 'not over $5' break. However, battery-powered quartz movements are treated as electrically operated by CBP per all supplied rulings, making 9105.29 inapplicable absent a contrary CBP determination. |
| 9105.21.40 | With opto-electronic display only | 3.9% on the movement and case+ 5.3% on the battery | Covers electrically operated wall clocks with opto-electronic display only (rate: 3.9% on movement and case + 5.3% on battery). Inapplicable here because the product has an analog (not opto-electronic) display. |
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