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 silicone based 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 described as “a silicone based watch strap with a stainless steel net element added to the design, which fits Apple watches.” You indicated that the material composition of the watch strap is 50.6 percent stainless steel and 49.4 percent silicone. The watch band is designed to attach to the sides of the Apple watch and uses a buckle to fasten the watch to the user’s wrist. The buckle enables 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 silicone based 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 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