CLA-2-91:OT:RR:NC:N4:414

M. Jacqueline Simpson
J-A-V International Incorporated
500 Ocean Avenue
East Rockaway, NY 11518

RE: The tariff classification of a ladies’ wrist watch

Dear Ms. Simpson:

In your letter dated August 11, 2010, on behalf of M.Z. Berger & Co., Inc., you requested a tariff classification ruling. A sample of the wrist watch was submitted with your ruling request.

The submitted sample, identified as style number IMZ20-Q01, is a ladies’ battery operated quartz analog wrist watch, with no jewels. The watch features a gold-plated alloy case. The back of the watch is marked with the words “stainless steel back, Japan movement, Isaac Mizrahi Live”.

You have stated in your letter that the country of origin of the movement is Japan. The watch is assembled in China and the case, band and the battery are made in China. The band of the watch is made of equal parts of metal chain and leather strap. The metal chain portion of the band is made of alloy material with 0.15 microns of acid gold plating. The alloy chain portion and the leather portion of the band are equal in size. The metal alloy chain portion is valued at a higher value than the leather strap portion of the band. Also, the metal alloy chain portion is what is actually connected to the watch case. The combination metal alloy chain and leather strap watch band is considered to be a base metal watch band for tariff classification purposes.

The applicable subheading for the wrist watch will be 9102.11.10, 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; with strap, band or bracelet of textile material or of base metal, whether or not gold- or silver-plated; with gold- or silver-plated case. The rate of duty will be 44 cents each plus 6 percent ad valorem on the case plus 14 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.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division