CLA-2-91:RR:NC:MM:114 G86967

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 January 31, 2001, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. An illustrative sample of the Flower Bangle Watch was submitted with the ruling request.

The submitted Flower Bangle Watch, identified as item number PP 216200, is a battery operated quartz analog wrist watch in an oval shaped case with a hinged lid. There are no jewels in the movement. The watch features a hinged bangle silver tone bracelet. The watch case and bracelet are of silver tone base metal decorated with pink enamel and floral decals on the top surfaces. You have stated in your letter that the case and bracelet are constructed of base metal, plated with .10–.15 microns of PCP and an underplating of 10 microns of copper and 2 microns of miralloy (Ni free). The case has a stainless steel back. The face of the watch features the traditional Arabic numbers 1 through 12 around the periphery corresponding to the hours of the day. The watch has a round white dial with black numbers and silver tone hour, minute and second hands. You have indicated in your letter that Avon Products, Inc. contemplates importing from China.

Your sample is being returned as requested.

The applicable subheading for the Flower BangleWatch will be 9102.11.25, 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; 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 per cent 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