CLA-2-71:OT:RR:NC:N4 462
Brett Stewart
Michaels
3939 W .John Carpenter Frwy
Irving, TX 75063
RE: The tariff classification of jewelry findings from China
Dear Mr. Stewart:
In your letter dated March 27, 2025, you requested a tariff classification ruling.
The product under review is a jewelry findings kit. The kit consists of 45 iron fishhook earrings, 45 iron
earring posts, 30 iron/plastic earring back disks, 250 plastic earring stoppers, and 144 brass butterfly earring
backs.
The applicable subheading for the iron fishhook earring and the iron earring posts 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 general rate of duty will be 11%
ad valorem.
The applicable subheading for the 250 plastic earring stoppers will be 3926.90.9989, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for “Other articles of plastics and articles of other
materials of headings 3901 to 3914: Other: Other: Other.” The general rate of duty is 5.3 percent ad valorem.
The applicable subheading for the Iron/Plastic Earring Back Disks will be 7326.90.8688, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for other articles of iron or steel: other: other: other:
other: other. The rate of duty will be 2.9 percent ad valorem.
The applicable subheading for the Brass Butterfly Earring Backs will be 7419.80.5050, HTSUS, which
provides for other articles of copper, other, other…other. The rate of duty will be free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheadings 3926.90.9989, 7117.19.9000, 7326.90.8688, and 7419.80.5050, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 7117.19.9000, 3926.90.9989 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, 3926.90.9989, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 7326.90.8688 and 7419.80.5050, HTSUS, unless specifically excluded, are subject to an
additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99
subheading, i.e., 9903.88.03, in addition to subheadings 7326.90.8688 and 7419.80.5050, HTSUS, listed
above.
On March 12, 2025, Presidential proclamations 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 25 percent are reflected in Chapter
99, headings 9903.81.89 and 9903.81.90. Products provided by heading 9903.81.91 will be subject to a duty
of 25 percent upon the value of the steel content. At the time of entry, you must report the Chapter 99
heading applicable to your product classification, i.e., 9903.81.90, in addition to subheadings 7326.90.8688,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
Please note that derivative steel products admitted to a U.S. foreign trade zone under “privileged foreign
status” before March 12, 2025, and entered for consumption on or after March 12, 2025, may be subject to
additional duties under heading 9903.81.93, HTSUS.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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