CLA-2-91:OT:RR:NC:N3:348
Margaret Thomas
Samsung Electronics America Inc.
700 Sylvan Avenue
Englewood Cliffs, NJ 07632
RE: The tariff classification of watch straps from Vietnam
Dear Ms. Thomas:
In your letter dated August 21, 2025, you requested a tariff classification ruling. Illustrations of the product
were provided with this request
The Peakform band for Galaxy Watch Ultra, Model # ET-SBL70MBEGKR, is a watch band designed to fit a
smart device. You indicate the material composition of the watch strap is 75% Hydrogenated Nitrile
Butadiene Rubber (HNBR), 5% percent nylon, 9.5% titanium and 10.5% stainless steel. The watch band is
designed to attach the Galaxy Watch Ultra to the user's wrist, featuring a dedicated connection structure
(lugless) that directly attaches to the device itself.
Additional U.S. Note 2 to Chapter 91states, “Watch straps, watch bands and watch bracelets entered with
wrist watches and of a kind normally sold therewith, whether or not attached, are classified with the watch in
heading 9101 or 9102. Otherwise, watch straps, watch bands and watch bracelets shall be classified in
heading 9113.” Since the watch straps are not being entered with the watch, the product will be classified
under heading 9113, Harmonized Tariff Schedule of the United States (HTSUS)
The applicable subheading for the Model # ET-SBL70MBEGKR will be 9113.90.8000, HTSUS, which
provides for watch straps, watch bands and watch bracelets, and parts thereof: other: other. The rate of duty
will be 1.8 percent ad valorem.
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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
9113.90.8000, HTSUS, listed above.
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 Rosemarie Hayward at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division