OT:RR:NC:N3:348
Mr. Predrag Savva
1903 Watch Co.
1560 Sugarberry Drive
Forney, TX 75126-1399
RE: The country of origin and marking of an automatic wristwatch from Japan
Dear Mr. Savva:
In your letter dated August 21, 2026, you requested a country of origin and marking ruling on an automatic
wristwatch from Japan.
Styles 1903WC001-1 (black dial) and 1903WC001-2 (blue dial) are automatic wristwatches. The watches
feature Miyota 9039 movements containing 24 jewels, stainless-steel cases, and leather straps.
You state that the watch movements are manufactured in Japan, while the cases and straps are manufactured
in China. All components are assembled into complete watches in China.
According to HQ 306338, dated May 14, 2021, “CBP’s long-standing position has been that the origin of a
watch (excluding the strap, band or bracelet) is the country of assembly of the watch movement. Although
the addition of the hands, dial, case or watchband may add definition to the timepiece, it does not
substantially change the character or use of the watch movement, which is the essence of the watch.” In this
case, the movements of styles 1903WC001-1 and 1903WC001-2 are manufactured in Japan. Consequently,
the country of origin for the finished watches is Japan.
In order to satisfy the requirements of 19 U.S.C 1304, a watch must be legibly and conspicuously marked
with the name of the country of manufacture of the watch movement.
Section 134.43(b), Customs Regulations (19 CFR 134.43(b)), in conjunction with section 11.9, Customs
Regulations (19 CFR 11.9), provides that watches must be marked in accordance with the special marking
requirements set forth in Chapter 91, Additional U.S. Note 4 of the Harmonized Tariff Schedule of the
United States (HTSUS) (19 U.S.C. 1202). This note requires that any watch movement, or case provided for
in the subpart, whether imported separately or attached to any article provided for in the subpart, shall not be
permitted to be entered unless conspicuously and indelibly marked by cutting, die-sinking, engraving,
stamping, or mold-marking (either indented or raised), as specified in the provisions of this note. This
marking is mandatory. Customs has no authority for granting exceptions to the special marking requirements
for watches.
Section (a) of Additional U.S. Note 4 requires that watch movements shall be marked on one or more of the
bridges or top plates to show the country of manufacture and the name of the manufacturer or purchaser; and,
in words, the number of jewels, if any servicing a mechanical purpose as frictional bearings.
Section (c) of Additional U.S. Note 4 requires that watch cases shall be marked on the inside or outside of the
back cover to show the name of the country of manufacture, and the name of the manufacturer or purchaser.
The country of manufacture in these requirements refers to where the movements and cases are manufactured
rather than where the watch was made. The special marking must be accomplished by one of the methods
specified in the Additional U.S. Note 4, and using stickers is not an acceptable alternative
Your proposal to mark the watch case with the words “JAPAN MVMT” satisfies the marking requirements
of 19 U.S.C. 1304, provided it is legibly, indelibly, and permanently marked in a manner visible to the
ultimate purchaser in the U.S.
The country of origin of a watch strap, however, is determined separately from that of the watch movement.
HQ 306338 states “Concerning the bands, it is CBP’s position that a watch strap must be separately marked
with its country of origin when that country of origin is different from the country of origin of the watch.
CBP has reasoned that the watch strap maintains its separate identity as the attachment of the watch strap to
the watch does not effect a substantial transformation of the watch strap.”
In this case, the straps of styles 1903WC001-1 and 1903WC001-2 are made in China, and the movements are
made in Japan. Because the country of origin of the watches differs from the country of origin of the straps,
the straps must be marked with their own country of origin. To satisfy the requirements of 19 U.S.C § 1304,
the straps must be legibly marked in a conspicuous place with the name of the country of manufacture of the
watch band. Marking with secure hangtags is acceptable, as long as they remain on the watches until they
reach the ultimate purchaser.
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)
James P. Forkan
Director
National Commodity Specialist Division