The tariff classification of the Ladybug Clip Watch from China Dear Ms. De Silva:In your letter dated June 20, 2005, you requested a tariff classification ruling on the Ladybug Clip Watch. A representative sample of the watch was submitted with the ruling request.The Ladybug Clip Watch, item number PP 297119, is a battery operated quartz analog watch with a stainless steel case back, glass lens and brass dial. The watch case is in the shape of a ladybug. The wings open up to reveal the face of the watch so the user can see the time. The watch is attached to a stainless steel lobster claw jump ring by a loop extending from the top of the watch case. The watch can be clipped on anywhere (belt loops, backpacks, etc.) as an accessory. You indicate in your letter that the movement of the Ladybug Clip Watch is made in Japan and the watch is assembled in China. The movement is a quartz movement containing no jewels. The applicable subheading for the Ladybug Clip Watch will be 9102.91.

NY L85962 July 22, 2005 CLA-2-91:RR:NC:MM:114 L85962 CATEGORY: Classification TARIFF NO.: 9102.91.40 Ms. Stephanie De Silva Import/Export Analyst Avon Products, Inc. 1251 Avenue of the Americas New York, NY 10020 RE: The tariff classification of the Ladybug Clip Watch from China Dear Ms. De Silva: In your letter dated June 20, 2005, you requested a tariff classification ruling on the Ladybug Clip Watch. A representative sample of the watch was submitted with the ruling request. The Ladybug Clip Watch, item number PP 297119, is a battery operated quartz analog watch with a stainless steel case back, glass lens and brass dial. The watch case is in the shape of a ladybug. The wings open up to reveal the face of the watch so the user can see the time. The watch is attached to a stainless steel lobster claw jump ring by a loop extending from the top of the watch case. The watch can be clipped on anywhere (belt loops, backpacks, etc.) as an accessory. You indicate in your letter that the movement of the Ladybug Clip Watch is made in Japan and the watch is assembled in China. The movement is a quartz movement containing no jewels. The applicable subheading for the Ladybug Clip Watch will be 9102.91.40, 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; other; electrically operated; other; having no jewels or only one jewel in the movement. The rate of duty will be 40 cents each plus 6 percent ad valorem on the case plus 5.3 percent ad valorem on the battery. The sample is being returned as requested. 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