CLA-2-71:RR:NC:SP:233 L85319

Ms. Sharon McGinn
Moksha Worldwide Inc.
361 Park Avenue
Glencoe, IL 60022

RE: The tariff classification of imitation jewelry and key chains from China.

Dear Ms. McGinn:

In your letter dated May 27, 2005, you requested a tariff classification ruling.

The submitted samples are Style #4420 Bracelet, #6420 Necklace, #8410 Earrings, #7411 Key Chain, and #7410 Key Wrist Chain. The items are made of clay beads strung onto elasticized cord. The necklace and bracelet have no closure; the ends of the cords have been attached, forming a loop. The earrings each have a clay bead dangle and are designed for pierced ears. The key chain measures 3 ½” in length. A split metal key ring is attached to the end of it. Attached to the key ring is a metal carabiner. The key wrist chain is designed to be worn around the wrist. Attached to it is a split metal key ring. The clay beads in each of the items are composed predominantly of polyvinyl chloride (PVC) plastic. The beads impart the essential character of all of the jewelry items.

The applicable subheading for Style #4420 Bracelet, #6420 Necklace, and #8410 Earrings will be 7117.90.7500, Harmonized Tariff Schedule of the United States (HTS), which provides for “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Of plastics.” The rate of duty will be Free.

The applicable subheading for Style #7411 Key Chain will be 7616.99.5090, HTS, which provides for “Other articles of aluminum, Other.” The rate of duty will be 2.5% ad valorem.

The applicable subheading for Style #7410 Key Wrist Chain will be 7326.20.0070, HTS, which provides for “Other articles of iron or steel, articles of iron or steel wire, Other.” The rate of duty will be 3.9% 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