Country of origin of a wrist watch; Applicability of Section 301 duties on watch bands

N327631 August 24, 2022 CLA-2-91:OT:RR:NC:N1:113 CATEGORY: Country of Origin Mr. Davide DD Dallospedale Fossil Partners, L.P. 901 South Central Expressway Richardson, Texas 75080-7302 RE: Country of origin of a wrist watch; Applicability of Section 301 duties on watch bands Dear Mr. Dallospedale: In your letter dated August 12, 2022, you requested “a country of origin ruling related to wrist watch merchandise and the application of Section 301 duties on watch bands.” Pictures, product descriptions, and the component cost breakdown for the subject watch were submitted with your ruling request for our review. The product under consideration is identified as a Fossil analog wrist watch with no jewels in the movement, style number FS5476. The watch features a round silver white dial with second, minute, and hour hands, a rose gold colored stainless steel case with a stainless steel back, and a leather band/strap. You stated in your letter that “The movement and the watch battery are produced in Japan. The watch case is made in China. The watch band is made in Myanmar (Burma). The movement, battery, and watch band are imported and assembled with the watch case in China.” Regarding the country of origin of watches, HQ 306338 dated May 14, 2021, stated that “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.” The country of assembly of the watch movement in the subject watch is Japan, therefore, the country of origin of the Fossil wrist watch is Japan. With regard to the country of origin of the watch components of an imported watch, the country of origin of the movement, the case, and the battery is the country of assembly of the watch movement. Since the watch movement in the subject watch is assembled in Japan, the country of origin of the finished watch and its components including the movement, the case and the battery, will be Japan.    In HQ 306338, CBP stated that “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 from the watch as the attachment of the watch strap to the watch does not effect a substantial transformation of the watch strap. The country of origin of the leather watch band under consideration is Myanmar (Burma). Since the watch band is not substantially transformed when joined to the Japanese watches in China, the band remains a product of Mayanmar (Burma). Since the subject Fossil watches and the watch components (the movement, the case and the battery) are of Japanese origin, the Section 301 duties for Chinese origin products would not be applicable. Noting that the leather watch band in question is made in Myanmr (Burma), the band will not be subject to the Section 301 Trade Remedy. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Ann Taub at ann.taub@.cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division