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January 27, 1999

CLA-2-91:RR:NC:MM:114 D86725

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.10; 9102.91.40

Mr. Arlen T. Epstein
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of the Two-Tone Convertible Bezel Watch and Winnie the Pooh Clip Watch from China or Hong Kong

Dear Mr. Epstein:

In your letter dated January 13, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling. Samples of the watches were furnished with the ruling request.

The submitted item number PP 184699 is a set consisting of a woman’s battery powered quartz analog wrist watch, having no jewels in the movement with a gold-plated case, silver tone bracelet with gold tone links and stainless steel back. The dial and case feature one micron gold plating. The watch case measures approximately one inch in diameter and the strap measures approximately 7 inches in length and 1/2 inch in width. Included with the wrist watch is an extra clip buckle which lengthens the strap by 5/8 of an inch, as well as four interchangeable twist-on top rings (bezels). The bezels are in gold tone, sporty two-tone and gold tone with rhinestones. The fourth bezel, which is silver tone, is attached to the watch.

The submitted item number PP 180767 is a Winnie the Pooh Clip Watch. The watch is a battery powered quartz analog gold tone clip-on watch, having no jewels in the movement and stainless steel back. The watch case measures approximately one inch in diameter and is attached to a gold tone metal swivel snap clip by a loop extending from the bezel. The face of the watch has a picture of the Pooh Bear leaning against the printed word “POOH”.

Your samples are being returned as requested.

The applicable subheading for the Two-Tone Convertible Bezel Watch will be 9102.11.10, 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; with strap, band or bracelet of textile material or of base metal, whether or not gold- or silver-plated; with gold- or silver-plated case. The rate of duty will be 44 cents each plus 6 percent ad valorem on the case plus 14 percent ad valorem on the strap, band or bracelet plus 5.3 percent ad valorem on the battery. The value of the interchangeable bezels will be included in the value of the case and the value of the bracelet extension will be included in the value of the strap.

The applicable subheading for the Winnie the Pooh Clip Watch will be 9102.91.40, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, pocket watches and other watches, including stop watches, other than those of heading 9101; other; electrically operated; other; having no jewels or only one jewel in the movement. The rate of duty will be 40 cents each plus 6 percent ad valorem on the case plus 5.3 percent ad valorem on the battery.

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 212-637-7058.

Sincerely,

Robert B. Swierupski
Director,

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