CLA-2-71:OT:RR:NC:N4:441
Naqueb Rahman
Amgem, Inc.
30009 104TH AVE, SE
Auburn, WA 98092
RE: The tariff classification and applicability of subheading 9802.00.6000 of gold jewelry
Dear Mr. Rahman:
In your letter dated July 2, 2025, you requested a tariff ruling on various styles of hand-crafted gold jewelry.
You have submitted photographs, descriptive information, and manufacturing steps on necklaces, rings,
bracelets, and earrings.
The manufacturing steps are as follows:
United States
24 karat gold will be sourced and mixed with silver to achieve the desired karat.
United Arab Emirates (UAE)
1. Design is hand drawn
2. Drawing is converted to wax model
3. The wax is cast into a 21K or 22K gold jewelry
4. Gold pieces are cleaned and polished
5. Elements are assembled using hand tools and fine nozzle gas torches for soldering
You inquired about the applicability of subheading 9802.00.6000, Harmonized Tariff Schedule of the United
States (HTSUS), to the above-described gold jewelry.
Subheading 9802.00.6000, HTSUS, provides a partial duty exemption for:
[a]ny article of metal . . . manufactured in the United States or subject to a process of manufacture in
the United States, if exported for further processing, and if the exported article as processed outside
the United States, or the article which results from the processing outside the United States, is
returned for the United States for further processing.
In order for merchandise to qualify under subheading 9802.00.6000, HTSUS, four requirements must be met:
(1) the merchandise must be an article of metal; (2) the metal must either be manufactured in the United
States or subject to a process of manufacture in the United States; (3) the metal must be exported for further
processing; and (4) the metal must be returned to the United States for further processing.
For purposes of subheading 9802.00.6000, the term “metal” covers (1) the base metals enumerated in note 3
to section XV; (2) arsenic, barium, boron, calcium, mercury, selenium, silicon, strontium, tellurium, thorium,
uranium and the rare-earth elements; and (3) alloys of any of the foregoing. Gold is not a covered metal for
the purpose of subheading 9802.00.60. As such the first requirement is not met. Having failed the first
requirement, the jewelry has not met all four prerequisites and it is not eligible for special tariff treatment
under subheading 9802.00.6000.
The applicable subheading for the gold earrings, rings, and bracelets will be 7113.19.5090, HTSUS, which
provides for “Articles of jewelry and parts thereof, of precious metal or of metal clad with precious metal: Of
other precious metal, whether or not plated or clad with precious metal: Other: Other.” The general rate of
duty will be 5.5% ad valorem.
The applicable subheading for the gold necklace will be will be 7113.19.2900, 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 other precious metal, whether or not plated or
clad with precious metal: Other: Necklaces and neck chains, of gold: Other.” The general rate of duty will be
5.5% ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheadings
7113.19.5090 and 7113.19.2900, HTSUS, listed above.
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