The country of origin of watches from the Philippines

N351984
August 13, 2025
OT:RR:NC:N3:348
CATEGORY: Origin Gail Cumins Sharretts Paley Carter & Blauvelt P.C. 75 Broad Street New York City, NY 10004 United States RE: The country of origin of watches from the Philippines Dear Ms. Cumins: In your letter dated August 4, 2025, you requested a country of origin ruling on watches. No sample was provided; however, illustrations were included in the submission. The subject watch is a battery-operated analog watch with a quartz movement. The quartz movement contains no jewels. The watch case is made of base metal. The watch strap is constructed from stainless steel or leather, depending on the style. The manufacturing process in the Philippines is as follows: The watch movement is assembled from components sourced in China. Once the movement is assembled, it is installed in a base metal watch case with dial, hands, crown, bezel, sapphire and strap. The finished watch is exported to the United States. According to HQ 306338 dated May 14, 2021, “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 the Philippines, therefore, the country of origin is the Philippines. 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. Section 134.43(b), Customs Regulations (19 CFR 134.43(b)), in conjunction with section 11.9, Customs Regulations (19 CFR 11.9), provides that watches must be marked 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) (19 U.S.C. 1202). This note requires that any watch movement, or case provided for in the subpart, whether imported separately or attached to any article provided for in the subpart, shall not be permitted to be entered unless conspicuously and indelibly marked by cutting, die-sinking, engraving, stamping, or mold-marking (either indented or raised), as specified in the provisions of this note. This marking is mandatory. Customs has no authority for granting exceptions to the special marking requirements for watches. Section (a) of Additional U.S. Note 4 requires that watch movements shall be marked on one or more of the bridges or top plates to show the country of manufacture and the name of the manufacturer or purchaser; and, in words, the number of jewels, if any servicing a mechanical purpose as frictional bearings. Section (c) of Additional U.S. Note 4 requires that watchcases shall be marked on the inside or outside of the back cover to show the name of the country of manufacture, and the name of the manufacturer or purchaser. The country of manufacture in these requirements refers to where the movements and cases are manufactured rather than where the watch was made. The special marking must be accomplished by one of the methods specified in the Additional U.S. Note 4, and using stickers is not an acceptable alternative. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Rosemarie Hayward at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division