Mr. Michael S. O’Rourke
Rode & Qualey
55 West 39th Street
New York, NY 10018

RE: The tariff classification of complete, unassembled watch movements from Switzerland

Dear Mr. O’Rourke:

In your letter dated November 3, 2011 you requested a tariff classification ruling on behalf of Bedrock Manufacturing Co. (Bedrock).

Shinola/Detroit, LLC, an affiliate of Bedrock, will import the parts required to produce a watch movement from Switzerland. The parts will be unassembled at the time of importation. A button battery, which is made in the United States, will be imported with the watch movement parts. Dials, hands, stems, and other watch parts will be imported separately.

When assembled, the movement will have less than seven jewels and will measure 33.8 mm or less. The movement is a battery operated quartz watch movement and is referred to as the Shinola 705 movement. The backside movement production is a 27-step process and the dial side movement production is a 16-step process. The assembly of the watch movement will occur in the United States. The applicable subheading for the complete, unassembled watch movement will be 9110.11.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for complete watch or clock movements, unassembled or partly assembled (movement sets); of watches: complete movements, unassembled or partly assembled (movement sets). The rate of duty is the rate applicable to the complete, assembled movement. Watch movements, complete and assembled would be classified under subheading 9108.90.3000, HTSUS. Accordingly, the rate of duty applicable to the complete, unassembled movement classified under 9110.11.0000, HTSUS, will be 57 cents each.

Batteries entered with a complete watch movement, unassembled, and intended for use therewith are classifiable under the provision for such movement. Additional U.S. Note 3 to chapter 91, HTSUS, is noted.

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

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.


Robert B. Swierupski
National Commodity Specialist Division