CLA-2-91:OT:RR:NC:N3:348
9102.11.6530; 9102.11.6540; 9102.11.2510; 9102.11.2520; 9102.11.2530; 9102.11.2540
Richard Bennett
SEIKO Watch of America, LLC
2 Park Way, Suite 2A
Upper Saddle River, NJ 07458
RE: The tariff classification of four wristwatches from Japan
Dear Mr. Bennett:
In your letter dated December 22, 2025, you requested a tariff classification ruling on four wristwatches. No
sample was provided. Photos were included in the submission.
Style SBGY002 is described as an analog wristwatch with a spring drive movement containing 30 jewels.
The watch has a crocodile leather band. The front of the watch case, including the bezel, is made of 18k
gold. The back of the case is partially constructed from 18k yellow gold with a see-through sapphire crystal
opening. The watch does not operate by a battery. It is powered solely by a mainspring, eliminating the need
for batteries.
Style SBGC240 is described as an analog wristwatch with a spring drive movement containing 50 jewels.
The watch features a stainless-steel band and a stainless-steel case with an 18K yellow gold bezel. The watch
does not operate by a battery. It is powered solely by a mainspring, eliminating the need for batteries.
Style SUR363 is an analog wristwatch with a quartz movement with no jewels. The watch features a
stainless-steel band, stainless-steel case, and a battery.
Additional U.S. Note 2 to Chapter 91 states, “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.”
For style SBGY002, you have suggested classification under subheading 9102.11.95, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “wrist watches, electrically operated, whether or
not incorporating a stop watch facility: With mechanical display only: Other: Other: Other.” We agree with
your proposed classification. In accordance with Statistical Note 1 to chapter 91, HTSUSA, the applicable
classifications are as follows:
For the movement: 9102.11.9510, HTSUS. The rate of duty will be 76 cents each.
For the case: 9102.11.9520, HTSUS. The rate of duty will be 8.5 percent ad valorem.
For the band: 9102.11.9530, HTSUS. The rate of duty will be 2.8 percent ad valorem.
For the battery: 9102.11.9540, HTSUS. The rate of duty will be 5.3% percent ad valorem.
In accordance with Statistical Note 1 to Chapter 91, all individually named components, even if not included
in the shipment, must be identified even if the quantity is determined to be zero.
For style SBGC240, you have suggested classification under subheading 9102.11.50, HTSUS, which
provides for “wrist watches, electrically operated, whether or not incorporating a stop watch facility: With
mechanical display only: Other: With strap, band or bracelet of textile material or of base metal, whether or
not gold- or silver-plated, with gold- or silver-plated case.” We disagree with your proposed
classification. The case is constructed from stainless steel, not plated with gold or silver.
The applicable subheading for Style SBGC240 will be 9102.11.65, HTSUS, which provides for “wrist
watches, electrically operated, whether or not incorporating a stop watch facility: With mechanical display
only: Other: With strap, band or bracelet of textile material or of base metal, whether or not gold- or
silver-plated, with gold- or silver-plated case: Other.” In accordance with Statistical Note 1 to Chapter 91,
HTSUSA, the applicable classifications are as follows:
For the movement: 9102.11.6510, HTSUS, The rate of duty will be 76 cents each.
For the case: 9102.11.6520, HTSUS. The rate of duty will be 8.5 percent ad valorem.
For the band: 9102.11.6530, HTSUS. The rate of duty will be 14 percent ad valorem.
Fort the battery: 9102.11.6540, HTSUS. The rate of duty will 5.3% percent ad valorem.
In accordance with Statistical Note 1 to Chapter 91, all individually named components, even if not included
in the shipment, must be identified even if the quantity is determined to be zero.
For style SUR363, you suggested classification under subheading 9102.11.25, HTSUS, which provides for
“Wrist watches, electrically operated, whether or not incorporating a stop watch facility: With mechanical
display only: Having no jewels or only one jewel in the movement: With strap, band or bracelet of textile
material or of base metal, whether or not gold- or silver-plated: Other.” We agree with your proposed
classification. In accordance with Statistical Note 1 to Chapter 91, HTSUSA, the applicable classifications
are as follows:
For the movement: 9102.11.2510, HTSUS. The rate of duty will be 40 cents each.
For the case: 9102.11.2520, HTSUS. The rate of duty will be 8.5 percent ad valorem.
For the band: 9102.11.2530, HTSUS. The rate of duty will be 14 percent ad valorem.
For the battery: 9102.11.2540, HTSUS. The rate of duty will be 5.3 percent ad valorem.
In accordance with Statistical Note 1 to Chapter 91, all individually named components, even if not included
in the shipment, must be identified even if the quantity is determined to be zero.
In your letter, you also requested classification for style SSH180. We are unable to provide you with the
classification. Additional information is necessary to complete this request. Please provide the weight and
value for the ceramic and titanium components in the watch band.
If you decide to resubmit your request, please include all of the material that we have returned to you and
mail your request to Director, National Commodity Specialist Division, Customs and Border Protection, One
World Trade Center, Suite 51.200, New York, NY 10007, Attn: Binding Ruling Request. If your request was
submitted electronically, you can re-submit your request and the additional information electronically via the
following link: https://erulings.cbp.gov/s/.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division