- To : Automated Broker Interface
Subject: WATCHES & WATCH BANDS
TO : ALL ABI BROKERS.
FROM : LOUIS ALFANO
SUBJECT : MAR-WATCHES & WATCH BANDS
DATE : 11/04/93
INFORMATIONAL MESSAGE
PLEASE MAKE AVAILABLE TO IMPORTERS, BROKERS, ETC.
SUBJECT: "ASSEMBLED IN..." AS MARKING FOR WATCHES; AND
MARKING OF WATCH STRAPS/BANDS AFFIXED TO WATCHES
RECENTLY, TWO MATTERS RELATING TO THE MARKING OF WATCH BANDS AND
WATCHES HAVE COME TO OUR ATTENTION. IN ORDER TO ASSURE UNIFORM
TREATMENT IN THIS SENSITIVE AREA, WE ARE SUMMARIZING THEM FOR THE
INFORMATION OF CUSTOMS OFFICERS AND INTERESTED PARTIES.
"ASSEMBLED IN..." AS MARKING FOR WATCHES
ON OCTOBER 7, 1993, THE OFFICE OF REGULATIONS AND RULINGS ISSUED HRL
735251, WHICH STATES THAT "ASSEMBLED IN ¢COUNTRY OF ORIGIN|" IS NOT
ACCEPTABLE AS A COUNTRY OF ORIGIN MARKING UNLESS THE GOODS ARE
ASSEMBLED ABROAD OF U.S. COMPONENTS AND ELIGIBLE FOR IMPORTATION UNDER
HTSUS SUBHEADING 9802.00.80 (FORMERLY TSUS ITEM NO. 807.00).
WATCH IMPORTERS ARE BEING ALLOWED A SIX-MONTH GRACE PERIOD DURING WHICH
WATCHES MARKED "ASSEMBLED IN" WILL BE PERMITTED TO BE IMPORTED. AS OF
APRIL 7, 1994, WATCHES SO MARKED WILL NOT BE PERMITTED TO BE IMPORTED.
PLEASE SEE THE TEXT OF HRL 735251 FOR INFORMATION REGARDING WHAT
CONSTITUTES THE COUNTRY OF ORIGIN FOR A WATCH.
PLEASE ADVISE IMPORTERS TO NOTIFY THEIR SUPPLIERS TO CHANGE THEIR
MARKING PRACTICES IMMEDIATELY IN CONFORMITY WITH HRL 735251. THE GRACE
PERIOD IS INTENDED TO ALLOW PHASING OUT OF THE ERRONEOUS PRACTICE, NOT
TO CONTINUE IT TO ANY LONGER THAN NECESSARY.
MARKING OF WATCH BANDS AFFIXED TO WATCHES
IT HAS BEEN CUSTOMS' POSITION FOR MANY YEARS THAT WATCH STRAPS/BANDS
MUST BE SEPARATELY MARKED TO INDICATE THEIR COUNTRY OF ORIGIN, EVEN IF
ATTACHED TO A WATCH. THE ONLY EXCEPTION WOULD BE IF BOTH THE WATCH AND
ITS STRAP/BAND HAVE THE SAME COUNTRY OF ORIGIN, IN WHICH CASE THE BAND
NEED NOT BE SEPARATELY MARKED. PERTINENT RULINGS INCLUDE ORR RULING
77 0080 (A NOVEMBER 1976 RULING PUBLISHED BY THE CUSTOMS INFORMATION
EXCHANGE ON OCTOBER 21, 1977), HEADQUARTERS RULING LETTER (HRL) 731546
OF OCTOBER 27, 1988; HRL 733533 OF AUGUST 3, 1990 AND HRL 734565 OF
OCTOBER 16, 1992. THE TWO LATTER RULINGS ARE AVAILABLE TO THE PUBLIC
THROUGH THE CUSTOMS RULINGS DISKETTES AND THROUGH LEXIS.
IT MAY BE APPROPRIATE TO DELAY APPLYING THESE RULINGS TO PARTICULAR
IMPORTERS. IN RESPONSE TO AN INQUIRY REGARDING THIS REQUIREMENT,
HEADQUARTERS HAS DETERMINED THAT IF AN IMPORTER DEMONSTRATES A LACK OF
AWARENESS OF CUSTOMS' POSITION ON THE MARKING OF WATCH BANDS ATTACHED
TO WATCHES, AND THAT THE COMPANY HAS BEEN IMPORTING THEM WITHOUT SUCH
MARKINGS FOR A LONG PERIOD OF TIME, THE DISTRICT DIRECTOR SHOULD GRANT
THE IMPORTER A REASONABLE GRACE PERIOD BEFORE REQUIRING SUCH MARKING.
CUSTOMS QUESTIONS CONCERNING LEGAL MATTERS SHOULD BE DIRECTED TO THE
VALUE AND MARKING BRANCH, OFFICE OF REGULATIONS AND RULINGS (202)
482-7010. CUSTOMS OPERATIONAL QUESTIONS SHOULD BE DIRECTED TO THE
COMMERCIAL COMPLIANCE BRANCH, OFFICE OF TRADE OPERATIONS (202)
927-0005.