CLA-2-85:OT:RR:NC:N2:209
Gianluca Faraone
Njord Camping Compagnie
7661 Auguste Piccard
Montreal H1E5Z7
Canada
RE: The tariff classification of Smart Watches from China
Dear Mr. Faraone:
In your letter dated May 17, 2025, you requested a tariff classification ruling.
The two items concerned are consumer-grade smartwatches from China:
1. The Indestructible Smartwatch (Model: Njord-watch-pro)
2. The APEX Smartwatch (Model: apex-smartwatch-orange)
Both are manufactured by Wei Yu Long Industries (Shenzhen, China) and imported by Njord Gear Co.
(Canada). These smartwatches are Bluetooth-enabled wearables intended for health tracking and smartphone
notification relay. They require Bluetooth pairing to a mobile phone for all functions.
The Indestructible Smartwatch (Model: Njord Watch Pro) is a wrist worn Bluetooth-enabled electronic
device designed exclusively for use as a companion accessory to a host smartphone. This device does not
contain nor support any standalone communication, navigation, or internet functions. It operates solely via
Bluetooth Low Energy (BLE) connectivity and is not functional without pairing to a smartphone.
This smartwatch features/incorporates:
A 1.32-inch IPS full-color capacitive touchscreen display, enclosed in a reinforced polymer housing
with a metal bezel.
Biometric sensors capable of collecting health-related and motion data including: heart rate, blood
pressure (via non-medical optical estimation), blood oxygen saturation (SpO2), sleep duration and
basic sleep quality, step count and estimated calorie expenditure.
Bluetooth connectivity.
Displays call, SMS and app notification.
rechargeable Lithium battery.
Voice calls via Bluetooth tethered to smartphone.
Voice commands.
This smartwatch does not contain GPS, Wi-Fi, cellular connectivity, SIM card support, internal storage, or
app installation capability.
All collected data is transmitted to an App on a mobile smartphone via the Bluetooth connection for user
access (display) and analysis.
Each unit is imported in sealed retail packaging under the brand name Njord Gear, containing the
smartwatch, a charging cable, and quick start instructional materials. The packaging is labeled with the model
identifier “Njord Watch Pro” and is ready for direct sale to consumers without further modification.
The Njord Watch APEX is a wrist-worn Bluetooth smart device designed exclusively for use with a tethered
smartphone. It does not have any standalone communication, navigation, or internet capabilities. The APEX
model builds upon the baseline design of the Njord Watch Pro described above. It has enhancements in
durability, battery life, display technology, and biometric tracking precision, while remaining fully dependent
on a Bluetooth Low Energy (BLE) connection to a host device for operation and is not functional without
pairing to a smartphone.
This smartwatch features/incorporates:
A 1.43-inch ultra-bright AMOLED capacitive touchscreen display.
The unit is shock-resistant and rated IP69K waterproof.
Biometric sensors capable of tracking heart rate, blood oxygen saturation (SpO2), blood pressure
(non-medical optical estimation), sleep tracking with breakdown of light and deep sleep stages, step
count, estimated calories burned, stress levels (via heart rate variability), basic activity modes (walking,
running, cycling).
Bluetooth connectivity.
Displays call, SMS and app notification.
rechargeable Lithium battery.
Voice calls via Bluetooth tethered to smartphone.
Voice commands
The device does not include GPS, Wi-Fi, NFC, cellular radios, a SIM card slot, or internal data storage.
All sensor data is collected locally and transmitted to a companion mobile app through BLE. The watch’s
interface is icon-based, allowing the user to view real-time metrics and receive smartphone notifications
(calls, texts, app alerts), which are mirrored from the connected phone.
Each unit is imported in sealed, branded retail packaging under the Njord Gear brand. The retail box includes
the Njord Watch APEX device, magnetic charging cable, and quick start instructions. The external packaging
is labeled with the product and model name, and the watch is fully prepared for consumer sale at the time of
importation.
The applicable subheading for both models of smart watch, Indestructible Smartwatch (Model:
Njord-watch-pro) and APEX Smartwatch (Model: apex-smartwatch-orange) will be 8517.62.0090, HTSUS,
which provides for “Telephone sets, including smartphones and other telephones for cellular networks or for
other wireless networks; other apparatus for the transmission or reception of voice, images or other data,
including apparatus for communication in a wired or wireless network (such as a local or wide area
network)…: Other apparatus for transmission or reception of voice, images or other data, including apparatus
for communication in a wired or wireless network (such as a local or wide area network): Machines for the
reception, conversion and transmission or regeneration of voice, images or other data, including switching
and routing apparatus: Other.” The general rate of duty will be Free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8517.62.0090, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.32, in addition to subheading 8517.62.0090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8517.62.0090, 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 8517.62.0090, 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,
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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/.
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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division