CLA-2-71:OT:RR:NC:N4:441
David Murphy
GDLSK LLP
599 Lexington Avenue, 36th Floor
New York, NY 10022
RE: The tariff classification, country of origin, and marking of a silver bracelet from the United States
Dear Mr. Murphy:
In your letter dated June 10, 2025, you requested a tariff classification, country of origin, and marking ruling
on a silver bracelet. You have submitted photographs, product description, and manufacturing information
for our review.
Style Number B18729 SSM, is a bracelet made of sterling silver. The bracelet measures 6mm and is size
medium. It fits wrists up to 6.30 inches. The bracelet is valued over $18 per dozen.
You have indicated the following manufacturing steps will take place in the United States:
Molten silver is poured continuously into a mold and solidified while withdrawn from the bottom.
A silver rod or wire is pulled through a die. As it passes through, the diameter is reduced, and the
length increases. Multiple passes through progressively smaller dies may be needed to reach the
desired thickness.
The wires are then made into spools and loaded into a specialized cable twisting machine.
After the silver wire has been twisted into a core-supported cable configuration, the entire twisted
wire spool is formed into the final bangle geometry.
The wire is then uniformly coiled.
Once in its final form, the entire assembly undergoes the annealing process to restore the silver’s
original malleability
The annealed coil is subjected to a precision sawing operation. This step segments the coil into
uniform, rounded individual components using a fine-toothed saw blade, ensuring clean edges and
dimensional accuracy for subsequent processing or assembly.
The components are processed in a tumbling machine to enhance brightness and remove residual
oxides or burs from previous operations.
You have indicated the following manufacturing steps will take place in India:
A wax model of the end caps will be created.
Following the output from the lost wax casting process, the end caps undergo a filing and polishing
sequence before being attached to the bangles.
The bangles are submerged in a controlled oxidation bath and then polished.
Each article is stamped with a metal mark and/or any other special logo upon request is lasered on the
jewelry pieces.
The finished bracelet is shipped to the U.S.
The applicable subheading for the sterling silver bracelet will be 7113.11.5000, Harmonized Tariff Schedule
of the United States (HTSUS), which provides for “Articles of jewelry and parts thereof, of precious metal or
of metal clad with precious metal: Of precious metal whether or not plated or clad with precious metal: Of
silver, whether or not plated or clad with other precious metal: Other: Other.” The general rate of duty will
be 5% ad valorem.
Your request also concerns the eligibility of the finished bracelet under subheading 9802.00.5060, HTSUS.
Subheading 9802.00.5060, HTSUS, provides a partial or complete duty exemption for articles returned to the
U.S. after having been exported to be advanced in value or improved in condition by any process of
manufacture or other means, provided that the documentary requirements of Section 10, Customs
Regulations (19 CFR 10.8) are satisfied.
Pursuant to 19 CFR 10.8, the importer must submit a declaration executed by the person who performed the
repairs or alterations and a declaration of his own containing various attestations. Articles eligible under
subheading 9802.00.5060 are subject to duty upon the value of the repairs, alterations, processing, or
otherwise changes in condition abroad, pursuant to Note 3 to Subchapter II, Chapter 98, HTSUS.
We find the described foreign processing acceptable for the purposes of 9802.00.5060, HTSUS. Accordingly,
upon reimportation, the bracelet will be eligible for tariff treatment under 9802.00.5060, HTSUS, provided
the documentary requirements of 19 CFR 10.8 are satisfied.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
U.S., 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National
Hand Tool Corp. v. U.S., 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
You propose that the country of origin of this bracelet is the United States. We agree. The casting of the
bracelet in the United States provides the essence of the finished product. The addition of the end caps and
polishing do not substantially transform the casting. As a result, the country of origin of the bracelet is the U
nited States. Therefore, the finished bracelet will be considered a product of the United States for marking
purpose and for purposes of trade remedies. Since the country of origin will be the United States, the bracelet
will be excepted from country of origin marking requirements and will not be subject to additional trade
remedy measures, such as reciprocal or global tariffs.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Vikki Lazaro at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division