CLA-2-71:RR:NC:SP:233 K82771

Mr. Arthur W. Bodek
Grunfeld, Desiderio, Lebowitz,
Silverman & Klestadt LLP
399 Park Avenue, 25th Floor
New York, NY 10022-4877

RE: The tariff classification of a metal belt with drawstring pouch from China.

Dear Mr. Bodek:

In your letter dated January 26, 2004, on behalf of Liz Claiborne, Inc., you requested a tariff classification ruling.

The submitted sample is a belt constructed of brass with five charms together spelling “Juicy” hanging from the chain of the belt. Each charm is shaped in a different letter and is constructed of brass with numerous small glass stones on the front. At the point of closure, there is also a heart-shaped charm bearing the phrase ”Juicy Couture” and a separate charm in the shape of the letter J, both also constructed of brass. The belt is secured by means of a bar and ring closure, which is adjustable by virtue of the presence of four separate rings, spaced approximately two inches apart. The belt will be imported with a pouch constructed of an unlined lightweight cotton fabric with an elastic man-made fiber drawstring. The pouch, which contains no compartments, fittings, supports, or other structural elements, is printed on the outside with the “Juicy Couture” legend. The pouch is considered ordinary packing when imported together with the belt and is therefore not separately classifiable.

Your sample is being returned as requested.

The applicable subheading for the metal belt with drawstring pouch will be 7117.19.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other.” The rate of duty will be 11% ad valorem.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Lawrence Mushinske at 646-733-3036.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division