May 27 CBP Bulletin Proposes to Revoke Ruling on Marking of Wristwatches
In the May 27 issue of the CBP Customs Bulletin (Vol. 49, No. 21) (here), CBP published notices that propose to revoke or modify a ruling and similar treatment for the marking of country of origin of wristwatches.
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Comments on Proposals Due June 26
CBP said consideration will be given to any written comments received by June 26 before taking this action. In addition, any party who has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions, or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Wristwatches
| Item: Wristwatches assembled in China from analog quartz movements manufactured in Japan that control the hour and minute hands, and digital movements manufactured in China that show the seconds by means of a liquid crystal display. |
| Current: The country of the origin of the watches is Japan because displaying hours and minutes is the essential function of the watches. The watches are marked by a paper hangtag, with no country of origin marking on the watch plate or face. |
| Proposed: The watches' hangtags should be marked as “Analog Movement-Japan” and “Digital Movement China." The analog movement should be marked with the country of origin (Japan), the name of the manufacturer or purchaser, and the number of jewels. The watch case should be marked with the country of origin of the analog movement (Japan) and the name of the manufacturer or purchaser. |
| Reason: The country of origin of the wristwatches is the country of origin of the movement, and in this watch with two movements the country of origin of each movement must be marked. Additional Note 4 to Chapter 91 includes special marking requirements for the cases and movements of all watches that are not opto-electronic. As such, although the optoelectronic parts made in China are exempt, the analog parts of the watches made in Japan must still be marked in accordance with Additional Note 4. |
| Proposed for revocation: HQ 562543 |
| Proposed new ruling: HQ H243796 |