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NY M82496





May 16, 2006

CLA-2-91:RR:NC:MM:114 M82496

CATEGORY: MARKING

TARIFF NO.: 9102.11.10

Ms. Marilyn Cohen
I.L. Cohen Co., Inc.
225 Broadway
New York, NY 10007

RE: The marking of quartz analog wrist watches

Dear Ms. Cohen:

In your letter dated March 20, 2006, on behalf of E. Gluck Corp., you requested a ruling on two quartz analog wrist watches. You specifically ask in your letter whether bracelets with integrated watch cases are considered separate entities, and whether the bracelets require separate country of origin marking. We note that NY Ruling L85912 dated July 28, 2005 was issued to you on the classification and marking of these watches.

The submitted bangle watch, style number 10/7438, features a gold-plated bangle bracelet. The bracelet is permanently attached to the square gold-plated watch case. Style number 10/7438 is marked on the outside of the back of the watch case with the words “Thailand Movt.” and the bangle bracelet of the watch is marked with a paper hangtag with the words “China Bangle”.

The submitted charm watch, style number 10/7397, features a silver-plated chain with imitation pearls that wraps around the wrist of the wearer. The chain is attached to the top and the bottom of the round silver-plated watch case by silver-plated links. Style number 10/7397 is marked on the outside of the back of the watch case with the words “Thailand Movt.” and the bracelet is marked with a paper hangtag with the words “Bracelet China”.

Regarding whether the bracelets are separate entities, the bangle bracelet of style number 10/7438 and the chain with imitation pearls of style number 10/7397 are considered the straps, bands or bracelets of the watches.

You also inquire as to the country of origin marking of the watch straps/bands/bracelets. The watch movements will be assembled in Thailand of Swiss parts. The movements will be assembled into the watches in China. The country of origin of the straps/bands/bracelets, dials, crystals and hands is China.

Since the country of origin of the watches differs from the country of origin of the straps/bands/bracelets, the straps/band/bracelets must be marked with their country of origin. You are required to mark each strap, band or bracelet with the words “Bracelet China” or similar words. Hangtags, if sufficiently permanent to remain with the watches until they reach the ultimate consumer, are an acceptable means of marking the straps, bands or bracelets.

It is the opinion of this office that the samples you have submitted are properly marked with the Section 304 country of origin marking as required by the marking statute. The watches must also be marked in accordance with the special marking requirements of additional US Note 4 of chapter 91, HTSUS, which was addressed in NY Ruling L85912.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

Your samples are being returned as requested.

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.

Sincerely,

Robert B. Swierupski
Director,

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