Background

U.S. Customs and Border Protection has issued guidance on the entry/entry summary filing requirements for components of watches or clocks subject to Section 301 tariffs on products from China.

CBP states that imports of watches or clocks are currently reported in ACE with one country of origin on one entry summary line and the components of a complete watch or clock are apportioned by value pursuant to HTSUS Chapter 91, Statistical Note 1. All applicable duties and fees, to include Section 301 tariffs for all components, can be reported on one entry summary line when all the components have a country of origin of China or a country other than China.

However, when the band or case is made in China, if it is not substantially transformed when joined to other components and is subject to Section 301 tariffs, all the components need to be constructively separated into their component parts and each component must be separately valued and reported on separate entry summary lines in the order outlined in Chapter 91, Statistical Note 1. Functionality for such reporting became available in ACE as of Sept. 29.

If the band or case has a country of origin of China and the watch or clock has components of one or more additional countries of origin, filers will be required to break out the country of origin for each component 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 tariffs.

CBP adds that the commercial invoice must include a detailed description of the merchandise, materials, value, quantity, HTSUS classification, and country or countries of origin. Further, the invoice and supporting documents must provide sufficient information to determine the value, quantity, classification, and country or countries of origin of the components of the completed watch or clock.

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