THE COUNTRY OF ORIGIN MARKING OF WATCHES

N247202 November 13, 2013 MAR-2 OT:RR:NC:N4:414 CATEGORY: MARKING Mr. Will Beames Timex Group USA, Inc. 555 Christian Road Middlebury, CT 06762 RE: THE COUNTRY OF ORIGIN MARKING OF WATCHES Dear Mr. Beames: This is in response to your letter dated September 26, 2013, received in this office on October 24, 2013, requesting a ruling on the country of origin marking for a watch. This is a follow up letter to the ruling issued to Timex Group USA, Inc., New York ruling N245466 dated September 17, 2013, in which we addressed marking in accordance with Section 304 Tariff Act of 1930, as amended (19 U.S.C. 1304) and 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). This ruling letter addresses a proposed marking for the purposes of Section 304 Tariff Act of 1930, as amended (19 U.S.C. 1304). Please refer to New York ruling N245466 regarding the special marking requirements for watches of chapter 91, HTSUS. Model 20-20 Ana Digi wrist watch is a combination analog and digital wrist watch. The watch has a quartz analog movement and an opto-electronic module with a liquid crystal display. Both of the movements display the time in hours, minutes and seconds. The quartz analog movement is assembled in Japan of Japanese parts. The opto-electronic module is assembled in China with Japanese and Chinese parts. You propose marking the outside of the back of the watch with “Japan movement” and “China movement” and you provided a design drawing of the proposed country of origin marking. The marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the U.S. shall be marked in a conspicuous place as legibly, and permanently as the nature of the article (or container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain. The country of origin of a watch or clock is the country of manufacture of the watch or clock movement. The addition of the hands, dial, case, or watchband adds definition to the time piece -but does not change the character or use of the watch or clock movement. In order to satisfy the requirements of 19 U.S.C 1304, a watch must be legibly marked with the name of the country of manufacture of the watch movement in a conspicuous place. Model 20-20 Ana Digi wrist watch should be marked with both countries of origin. Your proposed marking of the country of origin for this wrist watch, for the purposes of Section 304 of the Tariff Act of 1930 as amended (19 CFR 1304), with the words “Japan movement” and “China movement” engraved on the outside of the back of the watch is considered conspicuous, legible and permanent in satisfaction of the marking requirements of 19 U.S.C. 1304 and 19 CFR Part 134. This ruling is being issued under provision of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Barbara Kiefer at (646) 733-3019. Sincerely, Gwenn Klein Kirschner Acting Director National Commodity Specialist Division