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NY L87917




October 6, 2005

CLA-2-91:RR:NC:MM:114 L87917

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.91.40; 7117.19.9000

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

RE: The tariff classification of a pendant watch and chain

Dear Ms. De Silva:

In your letter dated September 28, 2005, you requested a tariff classification ruling. Samples of a pendant watch and chain were submitted with the ruling request and are being returned as requested.

The submitted sample, item number PP 300516, is a marcasite heart pendant watch. The article is a heart-shaped covered pendant watch on a chain. The watch is a battery operated analog watch with a quartz movement containing no jewels. The watch case is constructed of zinc alloy plated and antiqued with palladium cobalt. The case has a stainless steel back. The front of the watch case features genuine marcasite stones and opens to reveal the face of the watch. The watch has a round brass dial with silver tone hour, minute and second hands. The watch case features a loop at the top center of the case for attaching to a rope link chain that measures approximately 33 inches in length. The chain is plated with palladium cobalt. You have indicated that the watch movement is made in Japan and the watch is assembled in China.

The applicable subheading for the pendant 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 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 646-733-3019.

Sincerely,

Robert B. Swierupski
Director,

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