March 31 CBP Bulletin Proposes to Modify Origin Rulings on Wristwatch Parts
In the March 31 Customs Bulletin (Vol. 55, No. 12), CBP published notices that propose to revoke or modify rulings on wristwatches produced in more than one country.
Comments on Proposals Due April 30
CBP said consideration will be given to any written comments received by April 30 before taking these actions. In addition, any party that 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 |
| Current: While the origin of wristwatches is based upon the origin of the movement, CBP said the assembly with watch cases and watch bands didn't result in a substantial transformation of those components. |
| Proposed: The watch cases should be considered a product of Japan or Malaysia, where the movement was made. |
| Reason: “The segregated components of the watch, i.e., the movement, case and battery, are assessed duty based upon the origin of the watch,” CBP said. “However, as the bands of the watches are not substantially transformed when joined to the Japanese or Malaysia watches in China or Thailand, the bands remain products of China.” |
| Proposed for modification: HQ H304105, dated June 25, 2019, and HQ H047115, dated June 22, 2009 |
| Proposed new rulings: HQ H306338 and HQ H315335 |