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NY M82353

May 8, 2006

CLA-2-91:RR:NC:MM:114 M82353


TARIFF NO.: 9102.11.45

Ms. Stephanie De Silva
Avon Products, Inc.
1251 Avenue of the Americas
New York, NY 10020

RE: The tariff classification of quartz analog wrist watch from China

Dear Ms. De Silva:

In your letter dated April 6, 2006, you requested a tariff classification ruling on a quartz analog wrist watch imported from China. A sample of the Best Teacher Watch was submitted with the ruling request.

Item number PP 353566, the Best Teacher Watch, is meant as a gift for a child’s teacher. The submitted sample is a battery operated quartz analog wrist watch in a round palladium cobalt plated (PCP) silver tone zinc alloy case with a stainless steel back. You state that the watch has a black plastic band. The face of the wrist watch features a picture of a pencil in the one o’clock position, a school house in the 3 o’clock position, a chalkboard in the 6 o’clock position, a school bus in the 9 o’clock position, and an apple in the 12 o’clock position. The watch has a round white dial with a yellow hour hand in the shape of a pencil and an orange minute hand in the shape of a ruler. The second hand is in the shape of a book. The movement of the watch is made in Japan and contains no jewels. The case and the bracelet will be manufactured in China and the watch will be assembled in 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 (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 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.

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.


Robert B. Swierupski

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