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NY K81064




December 4, 2003
CLA-2-91:RR:NC:MM:114 K81064

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.25; 9102.11.10

Ms. Stephanie De Silva
Import/Export Analyst
Avon Products, Inc.
1251 Avenue of the Americas
New York, NY 10020

RE: The tariff classification of quartz analog wrist watches

Dear Ms. De Silva:

In your letter dated November 10, 2003, you requested a tariff classification ruling on quartz analog wrist watches. Representative samples of the watches were submitted with the ruling request.

The submitted item number PP 271904 is identified as the Denim Cuff Watch. You have stated in your letter that item number PP 271904 consists of a Blue Denim Cuff Watch and a Red Denim Cuff Watch. The Blue Denim Cuff Watch is a women’s battery operated quartz analog wrist watch in a round silver tone zinc alloy case with a water resistant, nickel free, stainless steel case back. The case is not plated with gold or silver. The watch features a zinc alloy bracelet covered with blue cotton denim fabric. The face of the Blue Denim Cuff 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 round white brass dial with silver tone numbers and silver tone hour, minute and second hands. You have not stated in your letter the number of jewels, if any, in the movement. We agree with your proposed classification for the watch if the movement contains no jewels or only one jewel.

The Red Denim Cuff Watch is a women’s battery operated quartz analog wrist watch in a round gold tone zinc alloy case with a water resistant, nickel free, stainless steel case back. The case is plated with 23K gold. The watch features a zinc alloy bracelet covered with red cotton denim fabric. The face of the Red Denim Cuff 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 round white brass dial with gold tone numbers and gold tone hour, minute and second hands. You have not stated in your letter the number of jewels, if any, in the movement. We agree with your proposed classification for the watch if the movement contains no jewels or only one jewel.

You have indicated in your letter that the watch movements will be made in Japan, and the watches will be assembled in China. The watches will be imported with a Japanese Miyota battery. You have also indicated that you contemplate importing the watches from China.

Your samples are being returned as requested.

The applicable subheading for the Blue Denim Cuff 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.

The applicable subheading for the Red Denim Cuff Watch will be 9102.11.10, 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; with gold- or silver-plated case. The rate of duty will be 44 cents each plus 6 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 646-733-3019.

Sincerely,

Robert B. Swierupski
Director,

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