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NY F84099




March 17, 2000

CLA-2-91:RR:NC:MM:114 F84099

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.91.40; 7117.19.9000

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 pocket watches imported from China

Dear Mr. Epstein:

In your letter dated March 2, 2000, on behalf of Avon Products, Inc., you requested a tariff classification ruling on two quartz analog pocket watches. Samples of the Covered Pocket Watches were submitted with the ruling request.

The submitted Covered Pocket Watches, identified as PP 205923, are battery operated quartz analog pocket watches in base metal cases with detachable base metal chains. There are no jewels in the movements. You have indicated that Avon Products, Inc. contemplates importing from China.

The first pocket watch provided features a gold tone base metal case with a detachable gold tone base metal chain. The chain measures approximately 13 inches in length and is attached to a gold tone metal clip by a loop extending from the top of the case. 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 round dial with gold tone hour, minute and second hands. The watch has a hinged front cover with the word “DAD” embossed in raised block letters. The back of the watch is decorated with etchings depicting leaves.

The second pocket watch provided features a gold and silver tone base metal case with a detachable silver tone base metal chain. The chain measures approximately 13 inches in length and is attached to a silver tone metal clip by a loop extending from the top of the case. 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 round dial with black hour, minute and second hands. The watch has a hinged front cover decorated with a raised gold tone depiction of an eagle on a perch with its wings spread. The back of the watch is decorated with etchings depicting leaves.

Your sample is being returned as requested.

The applicable subheading for the Covered Pocket Watches 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.

The applicable subheading for the base metal watch chains will be 7117.19.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for imitation jewelry; of base metal, whether or not plated with precious metal; other; other; other. The rate of duty will be 11 percent ad valorem.

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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