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NY 806805

March 8, 1995

MAR-2 S:N:N8:344 806805


Mr. Norman Silverman
Time Tech Inc. (USA)
5858 Edison Place
Carlsbad, California 92008


Dear Mr. Silverman:

This is in response to your letter dated February 6, 1995 requesting a ruling on whether the proposed markings are acceptable country of origin markings for imported wrist watches.

You state in your letter that your watches are assembled in China and that the movements will be manufactured in either Japan or Singapore. You ask whether "Japan Quartz," "Product of Japan" or "Japan" would be an acceptable marking for your watches.

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article.

It has been the position of the U.S. Customs Service for many years that the country of origin of a watch or clock is the country of manufacture of the watch or clock movement. Accordingly, in order to satisfy the requirements of 19 U.S.C. 1304, a watch must be legibly marked with the name of the country of manufacture of the watch movement in a conspicuous place.

Your proposed markings are acceptable for those watches which contain movements made in Japan. The markings may be placed either on the dial or on the outside back case cover.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 177).

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


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