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NY I87167

October 29, 2002

CLA-2-91:RR:NC:MM:114 I87167


TARIFF NO.: 9102.11.45

Mr. Daniel Shapiro
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 Mr. Shapiro:

In your letter dated October 7, 2002, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. An illustrative sample of the Floral Cuff Watch was submitted with the ruling request.

The submitted Floral Cuff Watch, identified as item number PP 255375 is a women’s battery operated quartz analog wrist watch in a square silver tone zinc alloy case with a stainless steel back. There are no jewels in the movement. The watch features a lucite bangle bracelet containing a coral red floral pattern. You have stated in your letter that the watch case and hinged cuff of the bracelet are composed of zinc alloy plated with 10 microns of copper, 3 microns of miralloy and 0.10–0.15 microns of PCP. The face of the Floral Cuff Watch features the traditional Arabic numbers 6 and 12, and two silver toned squares to represent the numbers 3 and 9, around the periphery corresponding to the hours of the day. The watch has a square tinted pink brass dial with silver tone numbers and squares, 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 wrist watch will be 9102.11.45, 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; other; other. The rate of duty will be 40 cents each plus 8.5 percent ad valorem on the case plus 2.8 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 646-733-3019.


Robert B. Swierupski

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