Cargo Systems Messaging Service

CSMS #50019756 - Guidance: Entry/Entry Summary Reporting for Components of Watches or Clocks Subject to Section 301 China Duties

The purpose of this message is to provide guidance on the entry/entry summary filing requirements for components of watches or clocks subject to Section 301 trade remedies on products from China

BACKGROUND
Imports of watches or clocks are currently reported in 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. Please find below an example of how to enter a complete watch or clock with component(s) of Chinese origin that are not substantially transformed, retain a country of origin of China, and are subject to Section 301 duties. See HQ Ruling H304105 and H306338.

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.

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.

Please see the example below.

Example
An importer submits an entry for 1,137 complete watches. The value of the 1,137 watches (including the case, strap, band or bracelet, battery, and movement) classified under HTSUS 9102.11.25 is $154,700.22. This includes the costs of the components and the costs to produce the 1,137 watches. The movements from Japan cost $133,176.81, the cases from Japan cost $11,370, the bands from China cost $8,789.01 and the batteries from Japan cost $1,364.40. The bands were made in China and are subject to Section 301 duties.

Because the watch contains Chinese and non-Chinese components from various countries of origin, each component breakout will need to be reported on a separate entry/entry summary line with the appropriate statistical suffix. See Example 1 in the attached workbook. Note that the actual HTSUS numbers and duty rates due on an entry/entry summary line may differ from the example.

The attached spreadsheet provides additional examples of the correct entry summary reporting for complete watches and/or clocks.

ADDITONAL INFORMATION
To comply with CBP invoice requirements, the commercial invoice must include a detailed description of the merchandise, materials, value, quantity, HTSUS, and country or countries of origin (See 19 C.F.R. § 141 Subpart F for full requirements). The invoice and supporting documents must provide sufficient information to determine the value, quantity, HTSUS classification, and country or countries of origin of the components of the completed watch or clock.

Questions related to Section 301 entry-filing requirements, please refer to CSMS message #42203908 (Information on Trade Remedy Questions and Resources) https://content.govdelivery.com/accounts/USDHSCBP/bulletins/283fb04.