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NY 896931

May 4, 1994

CLA-2-91:S:N:N8:344 896931


Mr. Troy E. Clarke
CBT International, Inc.
110 West Ocean Blvd. - Suite 1003
Long Beach, California 90802

RE: The country of origin marking on analog watches.

Dear Mr. Clarke:

In your letter dated April 12, 1994, on behalf of Sunburst Products, Inc., you requested a binding ruling on country of origin marking for analog watches.

You state in your letter that the watches to be imported will be assembled in Mainland China from Japanese components. You further state that the movement of the watch is wholly of Japanese origin and will be assembled in Japan where it will then be exported to China where it will be assembled into an analog watch.

You propose to have the marking die struck in legible English on the back of the case.

For purposes of section 304, the country of origin of a watch is the same as the country of origin of its movement. This marking may be placed on the face of the dial or on the outside surface of the back cover of the watch case. Your proposal to have the marking die struck in legible English on the back of the case is acceptable so long as it is on the outside surface of the back cover of the watch case.

An adhesive sticker may also be used for the section 304 marking so long as the sticker is affixed so securely that unless deliberately removed it will remain on the watch while it is in storage or on display and until delivered to the ultimate purchaser. This marking is intended to enable the ultimate purchaser to make an informed purchase decision based on the country of origin.

We are also enclosing a copy of the Special Marking Requirements specified in chapter 91, U.S. note 4, HTS. These are in addition to the country of origin marking requirements contained in section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304).

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire

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