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NY E89417




November 26, 1999

CLA-2-91:RR:NC:MM:114 E89417

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.10

Ms. Barbara Y. Wierbicki
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of quartz analog wrist watch

Dear Ms. Wierbicki:

In your letter dated November 3, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. A sample of the Photo Locket Bangle Watch was submitted with the ruling request.

The submitted Photo Locket Bangle Watch, identified as item number PP 198315, is a battery operated quartz analog wrist watch in a square shiny gold-plated case with a nickel and copper underplate and a stainless steel back. There are no jewels in the movement. The watch features a hinged bangle gold tone bracelet with a clasp. You have stated in your letter that the case and bracelet are plated with 0.25 microns of 23K gold, with a -/+ twenty percent variation, and have underplates of nickel and copper measuring 10 microns. The face of the watch features the traditional Arabic numbers 1 through 12 around the periphery corresponding to the hours of the day. The watch has a square white dial with gray numbers and gold tone hour, minute and second hands. The watch case features a hinged cover. The exterior of the cover is inlaid with faux mother of pearl and the interior is designed to accommodate insertion of a small photograph. 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 Photo Locket Bangle Watch will be 9102.11.10, 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; 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 per cent 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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