CLA-2-91:RR:NC:MM:114 H80178

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 April 24, 2001, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. A representative sample of the Ladies Crystal Accent Watch was submitted with the ruling request.

The submitted Ladies Crystal Accent Watch, identified as item number PP 225633, is a women’s battery operated quartz analog wrist watch in a round silver tone case with a stainless steel back. You have stated in your letter that the case is constructed of base metal plated with 10 microns of copper, 6 microns of nickel and .20 microns of PNP. There are no jewels in the movement. The stainless steel case back is marked “JAPAN movement”. The watch features a pink “jelly” plastic watch strap. The watch case is adorned with small imitation gemstones in a groove encircling the perimeter of the watch face. The face of the watch features silver tone indices, representing the numbers 1 through 12, around the periphery corresponding to the hours of the day. The watch features a round pink dial with silver tone hour, minute and second hands. You have indicated in your letter that Avon Products, Inc. contemplates importing from China.

You have stated in your letter that the Ladies Crystal Accent Watch will be offered in three styles, differing only in the color of the watch strap. The strap will be available in blue, pink or gray.

Your sample is being returned as requested.

The applicable subheading for the Ladies Crystal Accent 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 percent 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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division