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NY G81615




September 19, 2000

CLA-2-91:RR:NC:MM:114 G81615

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.91.40

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 pocket watch

Dear Ms. Wierbicki:

In your letter dated August 25, 2000, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog pocket watch. A sample of the Recognition Fob Watch was submitted with the ruling request.

The submitted Recognition Fob Watch, identified as item number PP 216977, is a battery operated quartz analog watch in a round gold-plated base metal case. The watch case features a stem and hinged loop at the top center of the case. You have stated in your letter that the case is constructed of base metal plated with 0.25 microns of 23 carat gold, with a +/- 20 percent variation. You have described the item as a ladies open faced pocket type watch which, after importation into the United States, will be attached to a brooch fitted with a clip for holding the watch. Although a sample of the brooch fitted with a clip was submitted for our review, the pocket watch will be imported separately. You have indicated in your letter that Avon Products, Inc. contemplates importing from China.

The Recognition Fob Watch has no jewels in the movement. The face of the watch features the Roman numerals III, VI, IX and XII around the periphery corresponding to the hours of the day. The watch has a round white dial with black hour, minute and second hands.

Your sample is being returned as requested.

The applicable subheading for the Recognition Fob 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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