Origin Breakout Required for Clock, Watch Parts, CBP Says

Watch and clock importers are required to include origin information about the components when subject to the Section 301 tariffs on goods from China, CBP said in an Nov. 8 CSMS message. "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," CBP said.

When the "band or case component of a watch or clock classified under" Harmonized Tariff Schedule heading 9101 through 9105 "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, CBP said. "The breakout will allow for the reporting of various countries of origin to pay proper duties on each component, including applicable 301 China duties."

The CSMS message also included a spreadsheet with "examples of the correct entry summary reporting for complete watches and/or clocks." The requirement follows a ruling modification on watch components (see 2104070012). CBP previously issued similar guidance for reporting origin on golf club components (see 2105190035) and pipe spools (see 2004220021) that may be subject to trade remedies.