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NY E89150

November 19, 1999

CLA-2-91:RR:NC:MM:114 E89150


TARIFF NO.: 9102.11.10

Ms. Barbara Y. Wierbicki
Tompkins & Davidson, LLP
One Astor Place
1515 Broadway
New York, N.Y. 10036-8901

RE: The tariff classification of a wrist watch with interchangeable bracelets and bezels from China

Dear Ms. Wierbicki:

In your letter dated October 26, 1999, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a wrist watch with three interchangeable bracelets and bezels .

The wrist watch is a battery operated analog watch with a quartz movement which contains no jewels. The watch has a gold-plated case, a white colored dial with gold hands and Arabic numerals. The watch has three interchangeable metal bracelets and three metal bezels. There is a gold colored bracelet and bezel (the bezel is inlaid with 26 faux diamonds), a silver colored bracelet and bezel, and a black colored “enamel” bracelet and bezel.

Your sample is being returned as requested.

The watch is classifiable as a wrist watch in heading 9102, Harmonized Tariff Schedule of the United States. The interchangeable bracelets are simply different wrist bracelets for the wrist watch and are classifiable with the wrist watch. The value of the three interchangeable bracelets is included in the value of the straps, bands or bracelets. The interchangeable bezels are classifiable with the wrist watch. The value of the three interchangeable bezels is included in the value of the watch case.

The applicable subheading for the wrist watch will be 9102.11.10, Harmonized Tariff Schedule of the United States (HTS), which provides for 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 on the case plus 14 percent on the strap, band or bracelet plus 5.3 percent 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 212-637-7058.


Robert B. Swierupski

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