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April 14, 1999

CLA-2-91:RR:NC:MM:114 E80546

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.45

Mr. Louis S. Shoichet
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of wrist watch from China

Dear Mr. Shoichet:

In your letter dated April 8, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a wrist watch. A sample of the Faux Tortoise Fashion Watch was submitted with the ruling request.

The submitted Faux Tortoise Fashion Watch, identified as item number PP 187374, is a women’s battery operated quartz analog wrist watch in a shiny silver tone base metal case with a stainless steel case back. There are no jewels in the movement. The watch features a plastic faux tortoise bracelet. The bracelet opens by means of metal hinges. The face of the watch features the traditional Arabic numbers 3, 6, 9 and 12 around the periphery corresponding to the hours of the day. The watch has a square dial with hour, minute and second hands. You have indicated in your letter that Avon Products, Inc. contemplates importing from China.

Your sample is being returned as requested.

The applicable subheading for the wrist watch will be 9102.11.45, 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; 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.

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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