CLA-2-70:OT:RR:NC:N1:126

Tom Gould
Amanda Levitt
Sandler, Travis & Rosenberg, P.A.
505 Sansome Street, Suite 1475
San Francisco, CA 94111

RE: The tariff classification of a watch glass protector from China

Dear Mr. Gould and Ms. Levitt:

In your letter dated January 22, 2019, on behalf of your client, Belkin International, you requested a tariff classification ruling.

The merchandise under consideration is referred to as "Watch Glass Protector, SKU F8W917" for the Apple Watch (38 millimeter). A representative sample was submitted with your ruling request and was forwarded to the Customs and Border Protection Laboratory for analysis. This analysis has now been completed. The sample, which was requested to be returned, was destroyed during the process of analysis.

The sample of the "Watch Glass Protector, SKU F8W917", is a watch glass protector which is composed of clear glass that has been chemically strengthened by an ion-exchange process. It measures 1.38 inches long by .98 inches wide and is .012 inches thick. The "Watch Glass Protector, SKU F8W917" is shaped to fit over the Apple Watch to provide a protective barrier against scratches and normal wear and tear. From information you provided, you state the watch glass protector is designed to the precise dimensions and curve of the watch glass that sits flush underneath in order to protect the watch glass from scratches and/or breakage. You also state, the watch glass protector is curved, bent, or hollowed.

The laboratory analysis has determined that the "Watch Glass Protector, SKU F8W917", is composed of chemically tempered safety glass and has curved and beveled edges.

The applicable subheading for the "Watch Glass Protector, SKU F8W917" will be 7015.90.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Clock or watch glasses and similar glasses...: Other: Other". The general rate of duty will be Free.

Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.

Products of China classified under subheading , 7015.90.5000, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading , 7015.90.5000, HTSUS, listed above.

The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.

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 the World Wide Web at https://hts.usitc.gov/current.

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 Elena Pietron at elena.m.pietron@cbp.dhs.gov.

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division