Sandler, Travis & Rosenberg, P.A.
505 Sansome Street, Suite 1475
San Francisco, CA 94111
RE: The tariff classification of a watch glass from China. Correction to Ruling Number N302629.
Dear Mr. Gould and Ms. Levitt:
This replaces Ruling Number N302629, dated January 22, 2019, which contained a clerical error. The additional tariff number, 9903.88.03, Harmonized Tariff Schedule of the United States (HTSUS) was incorrectly listed in the Ruling. A complete corrected ruling follows.
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 glass screen 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 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, HTSUS, which provides for "Clock or watch glasses and similar glasses...: Other: Other". The general rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 7015.90.5000, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 7015.90.5000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.
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 email@example.com.
Steven A. Mack
National Commodity Specialist Division