CLA-2-71:OT:RR:NC:N4:433
Troy Clarke
CBT International, Inc.
249 East Ocean Boulevard, Suite 650
Long Beach, CA 90802
RE: The tariff classification of a bracelet from China.
Dear Mr. Clarke:
In your letter dated March 5, 2019, you requested a tariff classification ruling on behalf of your client Imperial Toy LLC. A description and sample were received.
Imperial Toy model number 23628, “Shine Secrets™ Sequin Slap Bracelet,” is an adjustable bracelet consisting of a metal band covered in a fabric sleeve. The face of the bracelet is embellished with sequins that change color when swiped back and forth.
You propose classification in subheading 7117.90.75, Harmonized Tariff Schedule of the United States, (HTSUS), based on the essential character of the plastic sequins.
The Explanatory Notes (ENs) to the HTSUS constitute the official interpretation of the tariff at the international level. EN VIII to General Rule of Interpretation (GRI) 3(b) provides: “the factor which determines essential character will vary as between different kinds of goods. It may, for example, be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods.” When the essential character of a composite good can be determined, the whole product is classified as if it consisted only of the material or component that imparts the essential character to the composite good.
The bracelet is composed of different components (base metal, fabric, and plastic) and is considered a composite good. The plastic sequins enhance the design and create the overall aesthetic appeal to the bracelet. This office is of the opinion that the size, volume, and bulk of the plastic sequins impart the essential character to the bracelet.
The applicable subheading for model number 23628, “Shine Secrets™ Sequin Slap Bracelet,” will be 7117.90.7500, HTSUS, 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.
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 the World Wide Web at https://hts.usitc.gov/current.
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 Dharmendra Lilia at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division