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NY F83289




February 22, 2000

CLA-2-91:RR:NC:MM:114 F83289

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.10

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 quartz analog wrist watch

Dear Mr. Epstein:

In your letter dated February 15, 2000, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. A sample of the Let’s Talk Watch was submitted with the ruling request.

The submitted Let’s Talk Watch, identified as item number PP 204152, is a women’s battery operated quartz analog wrist watch. There are no jewels in the movement. You have stated in your letter that the watch features a nickel-plated base metal alloy case with a stainless steel back and a bezel that is acid plated with one to four micro inches of gold. The round shiny gold-plated bezel is imbedded with small rhinestones around the periphery. For tariff classification purposes the bezel is considered to be part of the watch case and the watch will be classified accordingly. In this instance, the watch has a nickel-plated metal case with gold-plated bezel. The watch case will therefore be gold-plated for tariff purposes.

The watch features an adjustable metal link bracelet with a clasp. The bracelet has a center column that is gold tone and two outside columns that are silver tone. The face of the watch features twelve imbedded rhinestones around the periphery corresponding to the hours of the day. The watch has round gold tone dial and gold tone hour, minute and second hands. You have indicated that Avon Products, Inc. contemplates importing from China.

Your sample is being returned as requested.

The applicable subheading for the Let’s Talk 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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