CLA-2-71:OT:RR:NC:N4 462
Vanessa Bracero
The Jewelry Group
1411 Broadway
New York, NY 10018
RE: The tariff classification of bangle set from China
Dear Ms. Bracero:
In your letter dated March 4, 2025, you requested a tariff classification ruling on behalf of The Jewelry
Group.
Sample ID number RL A3202A is identified as a “BR Bangle Set - SLV/CREAM.” The item is comprised of
a set of three bangle bracelets held together with a cable chain. The bracelet components include: two 2.6 mm
*2.5 brass wire, 1 Lauren zinc logo tag, one 1.5 brass cable chain, one 6mm brass bead, twelve 3mm brass
balls and one 7mm acetate bangle. The bangles will be packaged in a blister card and sold as a set.
In considering whether item number RL A3202A qualifies as a “set” for classification purposes, we refer to
the Explanatory Notes (ENs) to the HTSUS. The ENs constitute the official interpretation of the tariff at the
international level. EN X to GRI 3(b) provides: “for the purposes of this Rule, the term "goods put up in sets
for retail sale" shall be taken to mean goods which: (a) consist of at least two different articles which are,
prima facie, classifiable in different headings; (b) consist of products or articles put together to meet a
particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users
without repacking (e.g., in boxes or cases or on boards).” Item RL A3202A meets these conditions and will
be considered a set for customs purposes.
No one heading in the tariff schedule covers these components in combination; thus, General Rule of
Interpretation (GRI) 1 of the HTSUS cannot be used as a basis of classification. GRI 3 provides for goods
that are, prima facie, classifiable in two or more headings. GRI 3(b) provides that mixtures, composite goods
consisting of different materials or made up of different components, and goods put up in sets for retail sale
shall be classified as if they consisted of the material or component which gives them their essential
character.
You state in your letter that you believe that the bracelet set should be classified at 7117.90.7500. We
disagree. The base metal components predominate in both value and quantity. Accordingly, it is our opinion
that the base metal imparts the essential character.
The applicable subheading for item RL A3202A will be 7117.19.9000, Harmonized Tariff Schedule of the
United States (HTSUS), 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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 7117.19.9000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 7117.19.9000, HTSUS, listed above.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Sandra Sary at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division