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NY 815415




October 18, 1995

CLA-2-91:R:N3:344 815415

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.30; 7117.19.90

Mr. David A. Eisen
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway - 43rd Floor
New York, NY 10036-8901

RE: The tariff classification of a wrist watch/pendant watch and base metal chain necklace from China.

Dear Mr. Eisen:

In your letter dated October 2, 1995, on behalf of Avon Products, Inc., you requested a tariff classification ruling.

The submitted sample, PP 133672, is a wrist watch/pendant watch with a battery powered, quartz analog movement with no jewels in a gold plated case, a leather wrist strap and a base metal gold tone chain necklace. The watch head is designed to be worn either as a wrist watch or a pendant watch. The watch head features two "D-rings" (located at the top and bottom) for simple attachment to the wrist band or necklace. The watch dial features roman numerals, and two rows of imitation miniature pearls circled around the face.

The essential character of the wrist watch/pendant watch is derived from the wrist watch.

Your sample is being returned as requested.

The applicable subheading for the wrist watch/pendant watch will be 9102.11.30, Harmonized Tariff Schedule of the United States (HTS), which provides for Wrist watches, battery powered, whether or not incorporating a stop watch facility: With mechanical display only: Having no jewels or only one jewel in the movement: Other: With gold- or silver-plated case. The rate of duty will be 44 cents each plus 6% on the case plus 2.8% on the strap, band or bracelet plus 5.3% on the battery.

The applicable subheading for the base metal, gold tone chain necklace will be 7117.19.9000, HTS, which provides for Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other. The rate of duty will be 11% ad valorem.

This ruling is being issued under the provisions of Section 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 Stanley Schwartz at 212-466-5895.

Sincerely,


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