CLA-2-85:OT:RR:NC:N1:112

Ms. Theresa Search
Nine West Holdings, Inc.
180 Rittenhouse Circle
Bristol, PA 19007

RE: The tariff classification of a portable charger bracelet, a necklace USB flash drive pendant, and a bracelet link toggle LED notifier from China

Dear Ms. Search:

In your letter dated August 25, 2015, you requested a tariff classification ruling. The submitted samples are being returned.

The three samples subject to this ruling request are described as follows: a portable charger bracelet, (NW-F1705D); a necklace USB flash drive long pendant (AK-M2808); and a bracelet link toggle LED notifier, (AK-M2809). The portable charger bracelet is a composite good consisting of a USB charging cable and a bracelet. The bracelet is composed of a black leather strap with mini bands of imitation gold and crystal as well as with an imitation gold clasp on its top. When the clasp is opened, the bracelet converts to a USB cable, which can be plugged into an external port to charge a smartphone. The necklace USB flash drive long pendant is a composite good that consists of a locket pendant necklace of imitation gold and a USB memory device. The necklace has the AK Logo with semi-precious stone and is worn as a locket pendant. At the end of the necklace is a USB flash memory apparatus, encased in the locket pendant, which can be used to store and transmit data such as documents, pictures, and videos. This USB apparatus is imported unrecorded and cannot perform any function besides storing data, audio, and video. The bracelet link toggle LED notifier is a composite good that consists of a bracelet and a signaling device. This item is a white and imitation gold link toggle bracelet containing an LED light which notifies one of an incoming call. After being charged, the bracelet will light up with an LED light to signal the user about the incoming call. It is the opinion of this office that the electronic components impart the essential character of all three composite goods. The applicable subheading for the portable charger bracelet will be 8544.42.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Insulated wire, cableā€¦: Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors: Other: Of a kind used for telecommunications. The rate of duty will be Free.

The applicable subheading for the USB flash drive locket pendant necklace will be 8523.51.0000, HTSUS, which provides for Discs, tapes, solid-state non-volatile storage devices, "smart cards" and other media for the recording of sound or of other phenomena, whether or not recorded, including matrices and masters for the production of discs, but excluding products of Chapter 37: Semiconductor media: Solid-state non-volatile storage devices. The rate of duty will be Free.

The applicable subheading for the bracelet LED notifier will be 8531.80.0050, HTSUS, which provides for Electric sound or visual signaling apparatus...: Other apparatus: Other. The rate of duty will be 1.3 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Steven Pollichino at steven.pollichino@cbp.dhs.gov.

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division