CLA-2-91:OT:RR:NC:4:414

Mr. Edward B. Ackerman
Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP
399 Park Avenue, 25th Floor
New York, NY 10022-4877

RE: The tariff classification of watches suspended in a leather protective cover with a belt clip from Switzerland

Dear Mr. Ackerman:

In your letter dated October 8, 2009, on behalf of Prada USA Corp., you requested a tariff classification ruling. A sample of the watch was submitted with your letter and will be returned as requested.

The watch contains an electrically operated movement with four jewels. The Prada Milano trade name is displayed on the round shaped face of the watch. The watch features a stainless steel case surrounded by leather. The leather encasement is stitched to one end of a leather strap; the other end of the leather strap has a clip which can be clipped on to a belt loop. A protective leather cover slides down the leather strap over the watch.

The applicable subheading for the watch in a leather protective cover with a belt clip will be 9102.91.80, 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; other; electrically operated; other; other. The rate of duty will be 76 cents each plus 6 percent on the case plus 5.3 percent 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.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division