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

Ms. Jane Blonshteyn
M.Z. Berger & Company
29-76 Northern Blvd.
Long Island City, NY 11101

RE: The tariff classification of an analog wrist watch from China

Dear Ms. Blonshteyn:

In your letter dated August 23, 2011, you requested a tariff classification ruling. A sample of the wrist watch was submitted with your letter and will be returned as requested.

Style number GEN598-W01 is identified as an analog wrist watch with a quartz movement. The watch is battery operated and there are no jewels in the movement. The alloy watch case is flash plated with palladium nickel plating. The palladium nickel plating, also referred to as PNP, is 70 percent palladium and 30 percent nickel. The expansion (stretch) steel bracelet is also flash plated with palladium nickel plating. The back of the case is marked with the words Base Metal Bezel, Style GEN598, Battery 377, Japan Movement and Stainless Steel Back. The case, the bracelet and the battery will be made in China and the movement will be made in Japan. The watch will be assembled in China.

The applicable subheading for the analog quartz wrist watch will be 9102.11.25, 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: other. The rate of duty will be 40 cents each plus 8.5 percent ad valorem on the case plus 14 percent 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