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NY H80565

June 5, 2001

CLA-2-91:RR:NC:MM:114 H80565


TARIFF NO.: 9102.11.25

Ms. Barbara Y. Wierbicki
Tompkins & Davidson, LLP
Counselors At Law
One Astor Plaza
1515 Broadway
New York, New York 10036-8901

RE: The tariff classification of quartz analog wrist watch

Dear Ms. Wierbicki:

In your letter dated May 10, 2001, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. A sample of the Silvertone Watch with Semiprecious Stone Accents was submitted with the ruling request.

The submitted Silvertone Watch with Semiprecious Stone Accents, identified as item number PP 219939, is a women’s battery operated quartz analog wrist watch in a rectangular shiny silver tone base metal case with a stainless steel back. There are no jewels in the movement. The watch features a combination bangle and expansion bracelet of silver tone base metal. The bangle portion of the watch bracelet features a black agate 4 mm square insert on the top of each side. You have stated in your letter that the case and bracelet are constructed of base metal plated with .10-.15 microns of PCP and an underplating of 10 microns of copper and 2 microns of miralloy (Ni free). The face of the 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 rectangular black dial with silver tone numbers and silver tone hour, minute and second hands. You have indicated in your letter that Avon Products, Inc. contemplates importing from China.

Your sample is being returned as requested.

The applicable subheading for the Silvertone Watch with Semiprecious Stone Accents 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.

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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