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NY G86185




January 24, 2001

CLA-2-91:RR:NC:MM:114 G86185

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.91.40; 7419.99.5050; 7117.19.9000

Mr. Bernard D. Liberati
Morris Friedman & Co.
325 Chestnut Street (Suite 415)
Philadelphia, PA 19106-3883

RE: The tariff classification of quartz analog watch, stud and chain from Taiwan

Dear Mr. Liberati:

In your letter dated December 18, 2000, on behalf of Penn State Industries, you requested a tariff classification ruling on a quartz analog watch, stud and chain from Taiwan. Samples of the quartz analog watch, stud and chain were submitted with the ruling request.

The submitted item number PKMIKIT, is identified in your sales catalog as a Micro Clock Necklace Kit. The Micro Clock Necklace Kit consists of a quartz analog watch, stud and chain. The watch is a battery operated quartz analog watch in a round base metal case. The watch has no jewels in the movement. 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 and gold tone hour, minute and second hands. The sales catalog submitted with your request states that the Micro Clock Necklace Kit requires a circular wood frame with a 15/16 inch opening for inserting the watch. The wood frame is not included in the Micro Clock Necklace Kit. There is a plastic ring around the watch case to ensure a snug fit when the watch is inserted into the wood frame.

You have indicated that the watch will be imported with a chain and stud. The chain is composed of steel and is approximately 28 inches in length. The stud is composed of brass and is approximately ½ inch in length. The stud features a loop at the top center. The chain is attached to the loop extending from the top of the stud. The lower portion of the stud is threaded. The threaded portion of the stud is screwed into the top of the wood frame. The stud provides linkage between the wood frame and the chain.

The applicable subheading for the quartz analog 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.

The applicable subheading for the brass stud will be 7419.99.5050, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of copper, other; other; other; other; other. The rate of duty will be free.

The applicable subheading for the steel chain 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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