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NY G85783




February 12, 2001

CLA-2-91:RR:NC:MM:114 G85783

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. A sample of the Men’s Silvertone Link Sport Watch was submitted with the ruling request.

The submitted Men’s Silvertone Link Sport Watch, identified as item number PP 205750, is a man’s battery operated quartz analog wrist watch in a round silver tone base metal case with a stainless steel back. You have indicated in your letter that the Men’s Silvertone Link Sport Watch is water resistant and there are no jewels in the movement. The watch has a silver tone base metal bracelet with an adjustable snap lock fastener. You have stated in your letter that the case and bracelet are constructed of metal alloy plated with .10-.15 microns of PCP (underplating of 10 microns of copper and 2 microns of miralloy). The watch has a rotating silver tone bezel and the date is displayed at the 3 o’clock position. The face of the watch features glow in the dark indicators at the 1, 2, 4, 5, 6, 7, 8, 9, 10, 11 and 12 o'clock positions. The minutes are printed under each glow in the dark indicator. The watch features a round white dial with glow in the dark 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 Men’s Silvertone Link Sport 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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