CLA-2-71:OT:RR:NC:N4:441
David Murphy
GDLSK
225 East 57th Street
NYC, NY 10022
RE: The tariff classification and country of origin on silver, gold and platinum jewelry.
Dear Mr. Lehat, Esq.:
In your letter dated September 22, 2025, you requested a ruling on behalf of your client, Renaissance Jewelry
New York, Inc. (dba Verigold). You submitted photographs, product description, and manufacturing
information on several styles of jewelry for our review.
Style PC193348 is a gold cross pendant set with diamonds.
Style BF 790246 is a silver bracelet set with rubies and sapphires.
Style RA1552189LG D is a 14K gold ring set with diamonds.
Style RB1500156RDL is a platinum ring set with diamonds.
The manufacturing steps performed in the United States are as follows:
Alloying
The manufacturing steps performed in UAE are as follows:
Wax model created
Flask Preparation
Metal Casting
Cooling and Quenching
Pre-finishing and tumbling
The manufacturing steps performed in India are as follows:
Linking of bracelet castings together
Setting and final finishing.
thin surface coating of rhodium is applied
Logo engraving, and packaging
The applicable subheading for Styles PC193348 and RA1552189LG D will be 7113.19.5091, 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 other precious metal, whether or not plated or clad
with precious metal. The general rate of duty will be 5.5% ad valorem.
The applicable subheading for Style BF 790246 will be 7113.11.5000, 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 rate of duty will general be 5% ad valorem.
The applicable subheading for Style RB1500156RDL will be 7113.19.5025, 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: Of ISO standard platinum: Rings.
The general rate of duty will be 5.5% ad valorem
You proposed that the country of origin of the jewelry is United Arab Emirates (UAE). We agree. The
casting of the jewelry in the UAE provides the essence of the finished products. Setting the gems and
performing final finishing does not substantially transform the castings. As a result, the country of origin of
the jewelry is UAE. Therefore, the finished jewelry will be considered a product of the UAE for marking
purposes and for purposes of trade remedies.
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 of United Arab
Emirates will be subject to an additional ad valorem rate of duty of 10 percent. 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
subheading 7113.19.5091, 7113.11.5000 and 7113.19.5025 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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division