What Every Member of the 

Trade Community Should Know About: 

Classification and 

Marking of Watches 

and Clocks 

AN INFORMED COMPLIANCE PUBLICATION 

FEBRUARY 2012
Classification and Marking of Watches and Clocks 

February 2012 

NOTICE:

This publication is intended to provide guidance and information to the trade community. 

It reflects the position on or interpretation of the applicable laws or regulations by U.S. 

Customs and Border Protection (CBP) as of the date of publication, which is shown on 

the front cover. It does not in any way replace or supersede those laws or regulations. 

Only the latest official version of the laws or regulations is authoritative. 

Publication History 

First Published: May 2000 

Revised January 2004 

Revised June 2005 

Reviewed with No Changes March 2006 

Reviewed with No Changes February 2008 

Reviewed with No Changes March 2009 

Reviewed with No Changes February 2010 

Reviewed with No Changes January 2011 

Reviewed with No Changes February 2012 

PRINTING NOTE: 

This publication was designed for electronic distribution via the CBP website 

(http://www.cbp.gov) and is being distributed in a variety of formats. It was originally set 

up in Microsoft Word 2003®. Pagination and margins in downloaded versions may vary 

depending upon which word processor or printer you use. If you wish to maintain the 

original settings, you may wish to download the .pdf version, which can then be printed 

using the freely available Adobe Acrobat Reader®. 

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PREFACE 

On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation 

Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act, 

became effective. These provisions amended many sections of the Tariff Act of 1930 and 

related laws. 

Two new concepts that emerge from the Mod Act are “informed compliance” and “shared 

responsibility,” which are premised on the idea that in order to maximize voluntary compliance 

with laws and regulations of U.S. Customs and Border Protection, the trade community needs to 

be clearly and completely informed of its legal obligations. Accordingly, the Mod Act imposes a 

greater obligation on CBP to provide the public with improved information concerning the trade 

community's rights and responsibilities under customs regulations and related laws. In addition, 

both the trade and U.S. Customs and Border Protection share responsibility for carrying out 

these requirements. For example, under Section 484 of the Tariff Act, as amended (19 U.S.C. 

1484), the importer of record is responsible for using reasonable care to enter, classify and 

determine the value of imported merchandise and to provide any other information necessary to 

enable U.S. Customs and Border Protection to properly assess duties, collect accurate 

statistics, and determine whether other applicable legal requirements, if any, have been met. 

CBP is then responsible for fixing the final classification and value of the merchandise. An 

importer of record’s failure to exercise reasonable care could delay release of the merchandise 

and, in some cases, could result in the imposition of penalties. 

Regulations and Rulings (RR) of the Office of International Trade has been given a major role in 

meeting the informed compliance responsibilities of U.S. Customs and Border Protection. In 

order to provide information to the public, CBP has issued a series of informed compliance 

publications on new or revised requirements, regulations or procedures, and a variety of 

classification and valuation issues. 

This publication, prepared by the National Commodity Specialist Division of Regulations and 

Rulings is entitled "Classification and Marking of Watches and Clocks”. It provides guidance 

regarding the classification and marking of these items. We sincerely hope that this material, 

together with seminars and increased access to rulings of U.S. Customs and Border Protection, 

will help the trade community to improve voluntary compliance with customs laws and to 

understand the relevant administrative processes. 

The material in this publication is provided for general information purposes only. Because 

many complicated factors can be involved in customs issues, an importer may wish to obtain a 

ruling under Regulations of U.S. Customs and Border Protection, 19 C.F.R. Part 177, or to 

obtain advice from an expert who specializes in customs matters, for example, a licensed 

customs broker, attorney or consultant. 

Comments and suggestions are welcomed and should be addressed to U.S. Customs and 

Border Protection, Office of International Trade, Executive Director, Regulations and Rulings, 

799 9th Street N.W. 7th floor, Washington, D.C. 20229-1177. 

Sandra L. Bell 

Executive Director, Regulations and Rulings 

Office of International Trade 

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Classification and Marking of Watches and Clocks 

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CLASSIFICATION OF WATCHES AND CLOCKS.....................................7

Watches ...................................................................................................................... 7

Clocks ......................................................................................................................... 7

MARKING....................................................................................................8

Section 304 Marking................................................................................................... 8

Special Marking Requirements ............................................................................... 10

Methods of Marking ................................................................................................. 11

ADDITIONAL INFORMATION...................................................................13

The Internet................................................................................................................ 13

Customs Regulations ................................................................................................. 13

Customs Bulletin ........................................................................................................ 13

Importing into the United States ................................................................................. 14

Informed Compliance Publications............................................................................. 14

Value Publications...................................................................................................... 15

“Your Comments are Important”................................................................................. 16

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CLASSIFICATION OF WATCHES AND CLOCKS 

Watches 

Watches are classified in Chapter 91 of the Harmonized Tariff Schedule of the United 

States (HTSUS) under headings 9101 and 9102. Heading 9101 covers watches with 

cases of precious metal or of metal clad with precious metal. Heading 9102 covers 

watches other than those of heading 9101 (watches with cases which are not of 

precious metal or of metal clad with precious metal). Headings 9101 and 9102 include 

wristwatches and other watches. 

Watches are defined in Additional U.S. Note I (a), to Chapter 91, as embracing 

timepieces (including timepieces having special features, such as chronographs, 

calendar watches and watches designed for use in skin diving) of a kind for wearing or 

carrying on the person. Time pieces incorporating a stand, however simple, are not 

classified as watches. Common types of watches are wristwatches, pocket watches, 

pendant watches (the chains are separately classified), clip-on watches and stop 

watches. 

The term “watch movement,” as related to mechanical movements, is defined in Note 

3 to Chapter 91, HTSUS, as meaning a device regulated by a balance wheel and 

hairspring, quartz crystal or any other system capable of determining intervals of time, 

with a display or a system to which a mechanical display can be incorporated. Watch 

movements cannot exceed 12mm in thickness and 50mm in width, length or diameter. 

 

Clocks 

Clocks are classified under headings 9103, 9104, and 9105. Heading 9103 covers 

clocks containing watch movements other than clocks of 9104. Heading 9104 covers 

instrument panel clocks for vehicles, aircraft, spacecraft or vessels. Heading 9105 

covers other clocks, including alarm clocks, wall clocks, and desk clocks. 

Clock movements are defined in the HTSUS, in Additional U. S. Note 1 (d) to Chapter 

91, as devices regulated by a balance wheel and hairspring, quartz crystal or any other 

system capable of determining intervals of time, with a display or a system to which a 

mechanical display can be incorporated. Clock movements must exceed either 12mm in 

thickness or 50mm in width, length or diameter, or both. If a movement in a clock does 

not exceed either of these dimensions, 12mm in thickness or 50mm in width, length or 

diameter, the clock is considered a clock with a watch movement, classifiable in 

heading 9103. These types of clocks are commonly referred to as mini-clocks. It should 

also be noted that in addition to watches and clocks, certain timers and time switches 

are classified in Chapter 91, HTSUS. 

 

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MARKING 

Watches and clocks are required to be marked in accordance with two separate 

marking requirements. One is the country of origin marking requirements of Section 304 

of the Tariff Act of 1930, as amended (19 U.S.C. 1304). The other is the special marking 

requirements of Chapter 91, Additional Note 4, HTSUS ("Note 4"). Sections 134.43 (b) 

and 11.9, Customs Regulations, provide that clocks and watches must be marked in 

accordance with Chapter 91, Note 4, HTSUS. As discussed below, the requirements 

are complex and quite specific, especially those relating to the special marking 

requirements of Chapter 91. 

Section 304 Marking 

Under section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), every article of 

foreign origin entering the United States must be legibly marked with the English name 

of the country of origin unless there is an exception from marking provided for in the 

law. The purpose of marking is to inform the ultimate purchaser in the United States of 

the country in which the imported article was made. 

 

Marking must be conspicuous, legible, and permanent. As a general rule, 19 USC 1304 

marking requirements are best met by marking worked into the articles at the time of 

manufacture. For example, it is suggested that the country of origin of metal articles be 

die-sunk, molded in or etched. Although 19 USC 1304 permits pressure sensitive labels, 

paper stickers or hang tags, Customs prefers a more permanent form of country of 

origin marking on imported articles. 

 

• Under 19 U.S.C.1304, as interpreted by Customs, the country of origin of the 

movement of the watch or clock determines the country of origin of the watch or 

clock. Although the addition of the hands, dial, or case adds definition to the timepiece, 

they do not substantially change the character or use of the watch or clock movement, 

which is the essence of the watch or clock. Accordingly, a watch with one country of 

origin for the movement, another for the case, and another for the battery, is 

considered, for purposes of 19 USC 1304, to be a product of the country in which the 

movement was produced. The movement's country of origin should appear 

conspicuously and legibly on the dial face or on the outside of the back of the watch or 

clock. 

Watchbands (including watch straps) assembled to a watch in the same country where 

the movement is assembled are substantially transformed and become a product of 

that country. HRL 560471 dated January 5, 1997 is noted. In such a case, assuming 

that the country of origin marking of the watch is otherwise conspicuous, legible and 

permanent, the band is not required to be marked. In the situation where the watch and 

watchband are from different countries, and they are assembled together in another 

country, an importer should consider requesting a ruling on the country of origin of the 

watch and the watchband. 

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Classification and Marking of Watches and Clocks 

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• If a watch or clock is sold to the ultimate purchaser in a sealed package, and if the 

country of origin is not clearly visible on the watch or clock through the packaging, the 

container must also be marked to indicate the country of origin of the watch or clock. 

 

Acceptable markings for watches and clocks consist of just the name of the country of 

origin or the name of the country of origin preceded by “Made in,” “Product of” or similar 

words. Also acceptable is the use of the word “Movement” or an abbreviation such as 

“Mov't” or “Movt” along with the name of the country. Examples of acceptable markings 

for a watch or clock if the movement is assembled in Hong Kong would be: “Hong 

Kong,” “Hong Kong Movement,” “Movement Hong Kong,” or “MOVT Hong Kong.” The 

wording “Swiss Made” is another example of an acceptable marking if the country of 

origin is Switzerland. 

Where the parts of a movement are from one country, and the parts are assembled into 

a movement in a second country (the country of origin), the marking on the watch and 

clock may identify the country where the parts of the movement are made (in addition to 

the country of origin of the watch or clock), as long as the marking is in compliance with 

the requirements of 19 CFR 134.46. 19 CFR 134.46 provides that when the name of a 

place other than the country of origin appears on an imported article or its container, 

and the non-origin reference may mislead or deceive the ultimate purchaser as to the 

actual origin of the article, there shall appear, legibly and permanently, in close 

proximity to such place name, and in at least a comparable size, the name of the 

country of origin preceded by “Made in,” “Product of” or words of similar meaning. As an 

example, if the parts of the movement are made in Switzerland and the movement is 

assembled in China, markings such as “Swiss Parts/Made in China,” “Swiss 

Parts/Movement China,” “Swiss Parts/China Movement” are acceptable. 

Customs has allowed the phrase “Designed In” to be used in conjunction with country of 

origin information, for 19 USC 1304 marking purposes. The marking “Designed in USA, 

Made in (Country of Origin),” has been found to be an acceptable marking provided the 

words “Made In (Country of Origin)” appear in close proximity and in the same size 

lettering as the words “Designed in USA.” See HRL 560202 dated December 20, 1996. 

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Classification and Marking of Watches and Clocks 

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Special Marking Requirements 

Chapter 91, Additional U.S. Note 4, HTSUS, sets forth the special marking requirements 

for watches and clocks. Movements with opto-electronic displays only and cases 

designed for use with opto-electronic movements, whether entered as separate articles 

or as components of assembled watches or clocks, are excepted from the special 

marking requirements of Additional U.S. Note 4. Opto-electronic displays refer to two 

specific types of watch or clock displays. In order to be considered a watch or clock with 

an opto-electronic display, the article must have a liquid crystal display (LCD) or a light 

emitting diode display (LED). Watches and clocks with mechanical displays, also 

referred to as analog displays are subject to the special marking requirements of 

Chapter 91. A mechanical or analog display has a dial, which may have numbers 

representing the hours of the day on it, and often has an hour hand, a minute hand, and 

a second (sweep) hand. 

Additional U.S. Note 4 provides that the following markings are required for watches 

and clocks: 

 

• WATCH MOVEMENTS: Must be marked on one or more of the bridges or top plates 

to show the name of the country of manufacture; the name of the manufacturer or 

purchaser; and in words, the number of jewels, if any, serving a mechanical purpose as 

frictional bearings. 

 

• WATCH CASES: Must be marked on the inside or outside of the back to show the 

name of the country of manufacture and the name of manufacturer or purchaser. 

• CLOCK MOVEMENTS: Must be marked on the most visible part of the front or back 

plate to show the name of the country of manufacture; the name of the manufacturer or 

purchaser, and the number of jewels, if any. 

• CLOCK CASES: Must be marked on the most visible part of the outside of the back to 

show the name of the country of manufacture. 

A clock case must be marked in accordance with the special marking requirements, 

even though the clock contains a watch movement, and the watch case enclosing the 

movement is marked on the inside of the back with the name of the country of 

manufacture. HRL 735158 dated December 17, 1993, is noted. 

Clock cases embrace inner and outer cases, containers and housings for movements, 

together with parts or pieces, such as, but not limited to, rings, feet, posts, bases and 

outer frames which serve to complete the clock. Additional U.S. Note 1 (b) to Chapter 

91, HTSUS, is noted. Often a clock movement will have an inner case, which 

immediately surrounds the movement, and an outer case which surrounds the inner 

case and other parts of the clock. The outer cases must be marked in accordance with 

the special marking requirements of chapter 91. 

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In HRL 560866 dated November 30, 1998, Customs found that the cardboard exterior

which surrounded the parts of a clock and acted as an outer case, was a clock case and 

therefore subject to the special marking requirements of Note 4. In another ruling, it was 

determined that a ceramic figurine was the clock case for a certain clock and thus, the 

clock case had to be marked in accordance with Additional U.S. Note 4 to Chapter 91. 

HRL 559934 dated October 23, 1996, is noted. 

Customs has held that the special marking requirements of Chapter 91 apply, even 

when it is claimed that marking in the required way will cause tarnishing and corroding 

of the clock case, or damage the finish of the clock (HRL 559066 dated May 12, 1995, 

is noted). However, Note 4 does not require any additional marking indicating the 

number of jewels where a movement has no jewels. Accordingly, if a movement has no 

jewels, the marking “No (0) Jewels” is not required. See HRL 560636 dated January 26, 

1998. 

As noted, certain timers and time switches are also classified in Chapter 91, HTSUS. 

Timers which contain clock movements, as defined in Additional U.S. Note l(d), are 

subject to the special marking requirements of Chapter 91. HRL 561018 dated June 12, 

1998, is noted regarding kitchen timers. 

Any movement or case provided for in Chapter 91 of the HTSUS must be marked in 

accordance with the special marking requirements whether it is imported separately or 

attached to an article provided for in the chapter. The term “purchaser” means the 

purchaser in the United States by whom or for whose account the articles are imported. 

Section 11.9 (b), Customs Regulations, is noted. As the special marking requirements 

of Additional U.S. Notes are Congressionally enacted, Customs has no authority to 

grant exceptions. The HTSUS provides that movements or cases provided for in 

Chapter 91 shall not be permitted entry unless properly marked as provided in the 

special marking requirements. 

Methods of Marking 

The marking specified by Chapter 91 must be accomplished by use of cutting, diesinking, engraving, stamping (including by means of indelible ink) or mold-marking 

(either indented or raised). The use of pressure sensitive stickers, paper labels, 

hangtags or any other method not specifically mentioned in Additional U. S. Note 4 is 

not acceptable. 

The methods of marking specified in Chapter 91 have specific meanings: 

• Cutting means that the marking must be cut into the metal, plastic or other material 

used in the article. 

 

• Die-sinking means stamping with a hard metal die to permanently mark the metal, 

plastic or other material. 

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Classification and Marking of Watches and Clocks 

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• Engraving is to carve, cut or etch into the metal, plastic or other material. 

• Stamping is a process that is forcefully made and leaves a permanent imprint or 

impression. (Stamping includes indelible ink marking.) 

• Mold marking is marking that is part of the mold used to make the item. Mold marking 

can be either indented or raised. 

In summary, watches and clocks must be marked with their country of origin for 

purposes of 19 U.S.C. 1304, and in accordance with Part 134 of the Customs 

Regulations. Clocks and watches must also be marked in accordance with the special 

marking requirements of Additional U.S. Note 4, Chapter 91 of the HTSUS. 

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ADDITIONAL INFORMATION 

The Internet 

The home page of U.S. Customs and Border Protection on the Internet’s World Wide 

Web, provides the trade community with current, relevant information regarding CBP 

operations and items of special interest. The site posts information -- which includes 

proposed regulations, news releases, publications and notices, etc. -- that can be 

searched, read on-line, printed or downloaded to your personal computer. The web site 

was established as a trade-friendly mechanism to assist the importing and exporting 

community. The web site also links to the home pages of many other agencies whose 

importing or exporting regulations that U.S. Customs and Border Protection helps to 

enforce. The web site also contains a wealth of information of interest to a broader 

public than the trade community. For instance, the “Know Before You Go” publication 

and traveler awareness campaign is designed to help educate international travelers. 

 

The web address of U.S. Customs and Border Protection is http://www.cbp.gov

Customs Regulations 

The current edition of Customs and Border Protection Regulations of the United States 

is a loose-leaf, subscription publication available from the Superintendent of 

Documents, U.S. Government Printing Office, Washington, DC 20402; telephone (202) 

512-1800. A bound edition of Title 19, Code of Federal Regulations is also available for 

sale from the same address. All proposed and final regulations are published in the 

Federal Register, which is published daily by the Office of the Federal Register, National 

Archives and Records Administration, and distributed by the Superintendent of 

Documents. Information about on-line access to the Federal Register may be obtained 

by calling (202) 512-1530 between 7 a.m. and 5 p.m. Eastern time. These notices are 

also published in the weekly Customs Bulletin described below. 

Customs Bulletin 

The Customs Bulletin and Decisions (“Customs Bulletin”) is a weekly publication that 

contains decisions, rulings, regulatory proposals, notices and other information of 

interest to the trade community. It also contains decisions issued by the U.S. Court of 

International Trade, as well as customs-related decisions of the U.S. Court of Appeals 

for the Federal Circuit. Each year, the Government Printing Office publishes bound 

volumes of the Customs Bulletin. Subscriptions may be purchased from the 

Superintendent of Documents at the address and phone number listed above. 

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Classification and Marking of Watches and Clocks 

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Importing into the United States 

This publication provides an overview of the importing process and contains general 

information about import requirements. The current edition of Importing Into the United 

States contains much new and revised material brought about pursuant to the Customs 

Modernization Act (“Mod Act”). The Mod Act has fundamentally altered the relationship 

between importers and U.S. Customs and Border Protection by shifting to the importer 

the legal responsibility for declaring the value, classification, and rate of duty applicable 

to entered merchandise. 

The current edition contains a section entitled "Informed Compliance." A key component 

of informed compliance is the shared responsibility between U.S. Customs and Border 

Protection and the import community, wherein CBP communicates its requirements to 

the importer, and the importer, in turn, uses reasonable care to assure that CBP is 

provided accurate and timely data pertaining to his or her importation. 

Single copies may be obtained from local offices of U.S. Customs and Border 

Protection, or from the Office of Public Affairs, U.S. Customs and Border Protection, 

1300 Pennsylvania Avenue NW, Washington, DC 20229. An on-line version is 

available at the CBP web site. Importing into the United States is also available for 

sale, in single copies or bulk orders, from the Superintendent of Documents by calling 

(202) 512-1800, or by mail from the Superintendent of Documents, Government Printing 

Office, P.O. Box 371954, Pittsburgh, PA 15250-7054. 

Informed Compliance Publications 

U.S. Customs and Border Protection has prepared a number of Informed Compliance 

publications in the “What Every Member of the Trade Community Should Know 

About:...” series. Check the Internet web site http://www.cbp.gov for current 

publications. 

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Classification and Marking of Watches and Clocks 

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Value Publications 

Customs Valuation under the Trade Agreements Act of 1979 is a 96-page book 

containing a detailed narrative description of the customs valuation system, the customs 

valuation title of the Trade Agreements Act (§402 of the Tariff Act of 1930, as amended 

by the Trade Agreements Act of 1979 (19 U.S.C. §1401a)), the Statement of 

Administrative Action which was sent to the U.S. Congress in conjunction with the TAA, 

regulations (19 C.F.R. §§152.000-152.108) implementing the valuation system (a few 

sections of the regulations have been amended subsequent to the publication of the 

book) and questions and answers concerning the valuation system. 

Customs Valuation Encyclopedia (with updates) is comprised of relevant statutory 

provisions, CBP Regulations implementing the statute, portions of the Customs 

Valuation Code, judicial precedent, and administrative rulings involving application of 

valuation law. A copy may be purchased for a nominal charge from the Superintendent 

of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-

7054. This publication is also available on the Internet web site of U.S. Customs and 

Border Protection. 

The information provided in this publication is for general information 

purposes only. Recognizing that many complicated factors may be 

involved in customs issues, an importer may wish to obtain a ruling under 

CBP Regulations, 19 C.F.R. Part 177, or obtain advice from an expert 

(such as a licensed Customs Broker, attorney or consultant) who 

specializes in customs matters. Reliance solely on the general 

information in this pamphlet may not be considered reasonable care.

Additional information may also be obtained from U.S. Customs and Border Protection 

ports of entry. Please consult your telephone directory for an office near you. The 

listing will be found under U.S. Government, Department of Homeland Security. 

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16

“Your Comments are Important” 

The Small Business and Regulatory Enforcement Ombudsman and 10 regional 

Fairness Boards were established to receive comments from small businesses about 

Federal agency enforcement activities and rate each agency’s responsiveness to small 

business. If you wish to comment on the enforcement actions of U.S. Customs and 

Border Protection, call 1-888-REG-FAIR (1-888-734-3247). 

REPORT SMUGGLING 1-800-BE-ALERT OR 1-888-NO-DROGA 

Visit our Internet web site: http://www.cbp.gov