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How does US Customs Classify Watches with Chinese Components under Section 301?

Imports of watches or clocks are currently reported in U.S. Customs and Border Protection's Automated Commercial Environment (ACE) with one country of origin on one entry summary line. The components of a complete watch or clock are apportioned by value pursuant to Chapter 91, Statistical Note 1. All applicable duties and fees, to include Section 301 duties for all of the components, can still be reported on one entry summary line where all the components of a watch or clock have a country of origin of China, or all the components of a watch or clock have countries of origin other than China. Components of watches or clocks may have different countries of origin if a component is not substantially transformed when joined to other components of a watch or clock. The functionality for acceptance of proper entry/entry summary line reporting for watches and clocks is available in the Automated Commercial Environment (ACE) as of September 29, 2021.

USCBP GUIDANCE In circumstances where the band or case component in watches or clocks are made in China, if the band or case component(s) are not substantially transformed and are subject to Section 301 duties, then all of the components need to be constructively separated into their component parts and each component separately valued and reported on separate entry summary lines in the order outlined in Chapter 91, Statistical Note 1. If the band or case component of a watch or clock classified under heading 9101 through 9105 of the Harmonized Tariff Schedule of the United States (HTSUS), has a country of origin of China and the watch or clock has components of one or more additional countries of origin, then filers will be required to break out the country of origin for each component of the watch or clock on a separate entry/entry summary line with the apportioned value in the order outlined in, Chapter 91, Statistical Note 1. The breakout will allow for the reporting of various countries of origin to pay proper duties on each component, including applicable 301 China duties.

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