CLA-2-91:RR:NC:MM:114 L80320

Mr. Bradley Menard
Customs Compliance Manager
Fossil Partners
2280 N. Greenville Ave.
Richardson, TX 75082

RE: The tariff classification of quartz analog wrist watches

Dear Mr. Menard:

In your letter dated October 15, 2004, you requested a tariff classification ruling on two quartz analog wrist watches, Fossil item numbers FA1551 and FA1552. A non-working mock-up of item number FA1551 was submitted with the ruling request.

The submitted item number FA1551 is a battery operated quartz analog wrist watch in a stainless steel case with a leather strap. The watch has seven jewels in the movement. The face of the watch features four silver tone indices to represent the numbers 3, 6, 9 and 12 around the periphery corresponding to the hours of the day. The watch has a rectangular silver tone dial with silver tone hour and minute hands. You have indicated in your letter that the watch movement will be made in Thailand. You have also indicated that the case and strap will be made in China, and the watch will be assembled in China. Fossil item number FA1552 is the same watch but in a different color.

Your sample of Fossil item number FA1551 is being returned as requested.

The applicable subheading for the wrist watches, Fossil item numbers FA1551 and FA1552, will be 9102.11.95, 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; other; other; other; other. The rate of duty will be 76 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