CLA-2-91:OT:RR:NC:N5:113
Winnie Lam
Urban Armor Gear, LLC
Alton Parkway, Suite C Irvine, CA 92606
RE: The tariff classification of magnetic silicone Apple watch bands/straps from China
Dear Ms. Lam:
In your letter dated December 29, 2023, you requested a tariff classification ruling. A description and photographs of the Apple watch bands were submitted for our review.
The product under consideration is identified as a magnetic silicone watch strap that fits Apple watches. You stated that the “Material composition of this product is 46 percent magnet, 37 percent silicone and 17 percent lug adaptor. The strap does not have a classic buckle but uses magnets to fasten the watch strap.” The watch band is designed to be wrapped around the wrist and features a magnetic closure. The magnets enable the user to adjust the band to the size of their wrist and to ensure a strong closure and secure fit.
The applicable subheading for the magnetic silicone Apple watch bands will be 9113.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for watch straps, watch bands and watch bracelets, and parts thereof: other: other. The rate of duty will be 1.8 percent ad valorem.
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/current.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9113.90.8000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 9113.90.8000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Ann Taub at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division