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July 21, 1999

CLA-2-91:RR:NC:MM:114 E84046


TARIFF NO.: 9102.91.40

Mr. Arlen T. Epstein
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of quartz analog clip-on watch

Dear Mr. Epstein:

In your letter dated June 29, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog watch. A sample of the Pink Bubble Face Watch was submitted with the ruling request.

The submitted Pink Bubble Face Watch, identified as item number PP 189725, is a battery operated quartz analog watch in a heart-shaped shiny silver-tone metal enclosure. The enclosure features a removable heart-shaped back. The enclosure is attached to a silver-tone metal swivel snap clip and small heart-shaped trinket by a loop extending from the top of the enclosure. The metal enclosure will be made in China. Although you have identified the Pink Bubble Face Watch as a pendant watch, it is the opinion of this office that the Pink Bubble Face Watch is a clip-on watch.

The Pink Bubble Face Watch has no jewels in the movement. The movement will be made in Japan. 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 features a glass bubble watch face covering a round pink dial with black hour, minute and second hands.

The applicable subheading for the Pink Bubble Face 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.

You have also asked for a ruling on U.S. Customs marking requirements. This ruling will only address the classification issue involved. Our office will issue a separate ruling to you in the near future regarding the marking issue. At the time the ruling pertaining to the country of origin marking is issued, your sample will be returned as requested.

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.


Robert B. Swierupski

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