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NY D83038




October 22, 1998

CLA-2-91:RR:NC:MM:114 D83038

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.45

Ms. Joann Baik
Amko International, Inc.
10960 Millridge N. Drive
Suite 115
Houston, Texas 77070

RE: The tariff classification of a quartz analog watch (watch head)

Dear Ms. Baik:

In your letter dated September 24, 1998, you requested a tariff classification ruling.

The two submitted items, watch heads, are quartz analogue, battery operated, electronic watch movements in base metal cases with stainless steel backs. The submitted samples are watch heads only, without straps, bands or bracelets. The movements have no jewels. The lower portion of the face of the watch heads are marked "Japan Movement". You have indicated in your letter that the watch heads will be imported from Hong Kong. The face of the watch head features twelve evenly spaced small plastic imitation diamonds around the periphery corresponding to the hours of the day and a second hand. The upper portion of the face of the watch head is printed with the words "Jennie B" against a white background.

In your submitted letter it is indicated that the watch heads are mostly used for making mini-clock watches and sometimes for bracelet watches. You have provided pictures of the mini-clock assembly, bracelet watch assembly and painted dial assembly. The watch heads cannot be used by themselves without inserting them into a mount. A black rubber ring is attached on the side of the watch heads so they will not slip off the mount.

The applicable subheading for the quartz analog watch (the watch head) will be 9102.11.45, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, electrically operated, whether or not incorporating a stop watch facility; with mechanical display only; having no jewels or only one jewel in the movement; other; other. The rate of duty will be 40 cents each plus 8.5 percent ad valorem on the case plus 2.8 percent ad valorem on the strap, band or bracelet plus 5.3 percent ad valorem on the battery. The 2.8 percent portion of the compound rate of duty is inapplicable since the watch will be imported without the wrist attachment.

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 212-466-5685.

Sincerely,

Robert B. Swierupski
Director,

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