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NY G85780




February 15, 2001

CLA-2-91:RR:NC:MM:114 G85780

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.25

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 January 19, 2001, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. An illustrative sample of the Two-Tone Oval Link Watch was submitted with the ruling request.

The submitted Two-Tone Oval Link Watch, identified as item number PP 214497, is a battery operated quartz analog wrist watch in a silver tone case with a stainless steel back. The submitted illustrative watch is approximately 7 1/2 inches in length. You have stated in your letter that the final product will be approximately 8 inches in length and include a removable extender that is 1 inch in length. The Two-Tone Oval Link Watch features a link bracelet with a snap closure. The links are oval-shaped, composed of silver tone base metal, and measure approximately 7/8 inch in length. The silver tone links are joined by gold tone base metal links that measure approximately 1/4 inch in length. The case resembles a rectangular box that has been inserted into one of the oval silver tone links. You have stated in your letter that the case and bracelet are constructed of metal alloy and plated with .10-.15 microns of PCP and an underplating of 10 microns of copper and 2 microns of miralloy (NI free). There are no jewels in the movement. 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 white dial with black numbers and black 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 Two-Tone Oval Link Watch will be 9102.11.25, 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; other. The rate of duty will be 40 cents each plus 8.5 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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