CLA-2-91:RR:NC:MM:114 H81811

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 May 29, 2001, on behalf of Avon Products, Inc., you requested a tariff classification ruling on a quartz analog wrist watch. A sample of the Rhinestone Mother of Pearl Watch was submitted with the ruling request.

The submitted Rhinestone Mother of Pearl Watch, identified as item number PP 226692, is a women’s battery operated quartz analog wrist watch in a oval shiny gold-plated base metal case with a stainless steel back. You have stated in your letter that the case is constructed of base metal plated with .25 microns of 23K gold, with a +/- 20 percent variation, and an underplating of 10 microns of copper and 2 microns of miralloy. The crown is plated with 1 micron of 23K gold. There are no jewels in the movement. The watch features a black velvet-like strap with a gold-plated buckle. The face of the watch is inlaid with mother of pearl and features the traditional Arabic numbers 1 through 12 around the periphery corresponding to the hours of the day. The watch features an oval dial with black outlined gold tone numbers and gold tone hour, minute and second hands. The watch is adorned with 18 small rhinestones glued into a bezel type frame encircling the perimeter of the watch face. 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 Rhinestone Mother of Pearl Watch will be 9102.11.30, 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; other; with gold- or silver-plated case. The rate of duty will be 44 cents each plus 6 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