CLA-2-91:OT:RR:NC:N5:113
Ewa Szczepanski
Casio America, Inc.
570 Mt. Pleasant Ave. Dover, NJ 07801
RE: The tariff classification of a ring watch from China
Dear Ms. Szczepanski:
In your letter dated May 7, 2024, you requested a tariff classification ruling. A description and photographs of the subject watch were submitted for our review.
The merchandise under consideration is a ring watch, model number CRW-001. The ring watch is a battery operated digital watch with a case and a band of stainless steel. You stated that “The ‘band’ is a closed loop that enables the user to wear it on his/her finger. The ring is not sizeable and can be worn on any finger.” The ring watch features a digital time display, a dual time option (standard or military), an auto calendar, an alarm, a time signal by light, and a stopwatch. The subject watch is waterproof (3bar) and contains a replaceable silver oxide button battery that has a 2-year lifespan.
The applicable subheading for the ring watch, model number CRW-001, will be 9102.91.20, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Wrist watches, pocket watches and other watches, including stop watches, other than those of heading 9101: Other: Electrically operated: With opto-electronic display only. The rate of duty will be 3.9% on the movement and case + 5.3% on the battery.
You have proposed statistical suffixes for the movement, the case and the battery. Our office agrees that under Statistical Note 1(b) to Chapter 91 of the HTSUS, the statistical suffix for the movement and case will be 10, and the statistical suffix for the battery will be 20.
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 at https://hts.usitc.gov/.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9102.91.20, HTSUS, unless specifically excluded, are subject to an additional 7.5 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 9102.91.20, 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.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division