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NY M80806





February 9, 2006

CLA-2-91:RR:NC:MM:114 M80806

CATEGORY: CLASSIFICATION

TARIFF NO.: 9102.11.45

Ms. Jacqueline Jefferson
JAV International, Inc.
500 Ocean Avenue
East Rockaway, NY 11518-1235

RE: The tariff classification of quartz analog watches

Dear Ms. Jefferson:

In your letter dated January 30, 2006, on behalf of M.Z. Berger, you requested a tariff classification ruling on two styles of quartz analog watches. A sample of each style of watch was submitted with the ruling request.

Style number SHP1608-C94 is a man’s battery operated quartz analog wrist watch with a base metal case with a stainless steel back. There are no jewels in the movement. The watch has a round white dial with black hour and minute hands, and a red second hand. The watch is water resistant to 100 feet. The movement is made in Japan.

Style number SHP203-C94 is a woman’s battery operated quartz analog wrist watch with a base metal case with a stainless steel back. There are no jewels in the movement. The watch has a round white dial with black hour and minute hands, and a red second hand. The watch is water resistant to 100 feet. The movement is made in Japan.

As stated in your letter, each style of watch features a combination calf leather and nylon strap. The leather portion provides the connection between the watch case and the strap and attaches the buckle that secures the watch to a wearer’s wrist. You stated that the back of the watch strap is composed of leather. Additionally, the leather provides the predominate value of the watch strap. We find that the leather portion of the strap imparts the essential character to the watch strap. Therefore, the combination leather and nylon strap is considered a leather watch strap for tariff classification purposes.

The applicable subheading for the wrist watches will be 9102.11.45, Harmonized Tariff Schedule of the United States (HTSUS), 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 one jewel in the movement: other: other. The rate of duty will be 40 cents each plus 8.5 percent on the case plus 2.8 percent on the strap, band or bracelet plus 5.3 percent on the battery.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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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