CLA-2-73:RR:NC:N1:113 J87575

Ms. Lisa Vollmer
Fascinos Authentic Italian Charms
2582 S. Maguire Rd.#161
Ocoee, FL 34761

RE: The tariff classification of stainless steel links from Italy.

Dear Ms. Vollmer:

In your letter dated July 7, 2003, you requested a ruling on tariff classification.

The samples you provided are a variety of stainless steel links that can be broken into various lengths to be made into individual links or bracelets. Specifically, the importations consist of continuous stainless steel links of 36 links, and stainless steel links that are enameled and have an outline of 18K gold. The links will be taken apart and have names/dates lasered onto them individually.

In your letter, you suggest that the items be classified in heading 7115, HTS, heading 7117, HTS or heading 7222, HTS. Heading 7115 provides for other articles of precious metal or of metal clad with precious metal. These items are neither of precious metal, nor are they clad. Heading 7117 provides for imitation jewelry. The NIS for imitation jewelry is of the opinion that these articles are not imitation jewelry in their imported condition. Heading 7222 provides for shapes and sections of stainless steel. The present merchandise does not conform to the definition of articles of heading 7222, HTS in Chapter 72, Note 1(n), q.v.

The applicable subheading for this product will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other. The general rate of duty will be 2.9 percent ad valorem.

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

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, contact National Import Specialist James Smyth at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division