CLA-2-91:RR:NC:MM:114 L89704

Ms. Stephanie De Silva
Avon Products, Inc.
1251 Avenue of the Americas
New York, NY 10020

RE: The tariff classification of Men’s Analog/Digital Sport Strap Watch imported from China

Dear Ms. De Silva:

In your letter dated January 3, 2006, you requested a tariff classification ruling. A sample of the Men’s Analog/Digital Sport Strap Watch was submitted with the ruling request and is being returned as requested.

The submitted Analog/Digital Sport Strap Watch, item number PP 309923, is a man’s battery-operated watch with a quartz movement containing no jewels. The watch displays the day, date and time in analog and digital format. The watch has a zinc alloy case that is plated with PCP, a stainless steel case back, a fixed bezel, a flat crystal lens and a PVC strap. The watch features backlight, alarm and chime functions and is water resistant to 100 feet.

The applicable subheading for the Men’s Analog/Digital Sport Strap Watch will be 9102.19.40, 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; having no jewels or only one jewel in the movement; other. The rate of duty will be 32 cents each plus 4.8 percent ad valorem on the case plus 2.2 percent ad valorem on the strap, band or bracelet plus 4.2 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