RE: The tariff classification of a mechanical watch movement from Malaysia

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364094 August 25, 2026 CLA-2-91:OT:RR:NC:N3:348 CATEGORY: Classification TARIFF NO.: 9108.20.4000 Mr. David Hitchcock DHWATCHMODULE 1 Orlingbury Road Little Harrowden NN9 5BH United Kingdom RE: The tariff classification of a mechanical watch movement from Malaysia Dear Mr. Hitchcock: In your letter dated August 6, 2026, you requested a tariff classification ruling for a mechanical watch movement. In lieu of a sample, you provided an image and a product manual. The item, identified as “TMI NH35,” is a complete, assembled watch movement. It excludes a case and dial. The movement features a full gear train, escapement, rotor, date disc and temporary crown system. It is a mechanical movement, not electrically operated, incorporating both automatic (self-winding) and manual wind-up mechanisms. The movement measures approximately 5.5 millimeters (mm) in thickness and 27.5 mm in diameter, and contains 24 jewels. You suggested classification under subheading 9108.20.4000, Harmonized Tariff Schedule of the United States (HTSUS). We agree with your proposed classification. The applicable subheading for TMI NH35 will be 9108.20.4000, HTSUS, which provides for “Watch movements, complete and assembled: With automatic winding: Having over 17 jewels.” The general rate of duty will be free. You also inquired about the impact of shipment value and country of export on import duties. Please be advised that, effective August 29, 2025, commercial shipments and e-commerce international shipments valued under $800 are no longer eligible for duty-free treatment under 19 U.S.C. § 1321. Consequently, all commercial shipments, regardless of their value, are subject to the applicable duty rate based on the product’s country of origin.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 P. Forkan Director National Commodity Specialist Division