CLA-2-82:OT:RR:NC:N1:118
Fay Jin
GreatStar Industrial USA, LLC
9836 Northcross Center Court, Suite A
Huntersville, NC 28078
RE: The tariff classification and country of origin of a jewelry making tool kit
Dear Ms. Jin:
In your letter dated September 28, 2025, you requested a tariff classification and country of origin
determination for purposes of Section 301 and IEEPA duties.
The merchandise under consideration is a jewelry making kit. The pictures you provided indicate that the set
will be packaged in a specially fitted case with the following items:
1 – needle nose pliers (made in Vietnam)
1 – long nose pliers (made in Vietnam)
1 – bent nose pliers (made in Vietnam)
1 – wire cutting pliers (made in Vietnam)
1 – bead reamer (made in China)
1 – bead scoop (made in China)
The items are used in conjunction with each other to make beaded jewelry utilizing wire and chain. You
have stated that the kit will be packaged for retail sale in China, before importation into the United States.
Classification
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is made in accordance
with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes, classification
shall be determined according to the terms of the headings, and any relative section or chapter notes and,
unless otherwise required, according to the remaining GRIs taken in order. Goods that are, prima facie,
classifiable under two or more headings, are classifiable in accordance with GRI 3. GRI 3(a) states in part
that when two or more headings each refer to a part of the item in a set put up for retail sale, those headings
are to be regarded as equally specific, even if one heading gives a more precise description of the goods.
The jewelry making kit consists of at least two different articles that are, prima facie, classifiable in different
headings. It also includes articles put up together to carry out a specific activity (i.e., making jewelry).
Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the
set in question is within the term “goods put up in sets for retail sale.” GRI 3(b) states in part that goods put
up in sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they
consisted of the component which gives them their essential character. It is our view that the essential
character of the jewelry making kit is imparted by the pliers.
The applicable subheading for the jewelry making kit will be 8203.20.6030, HTSUS, which provides for
files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters,
perforating punches and similar handtools, and base metal parts thereof: pliers (including cutting pliers),
pincers, tweezers and similar tools, and parts thereof: other: other (except parts): pliers. The general rate of
duty will be 12¢/doz. + 5.5 percent ad valorem.
Country of Origin
Guidance in a situation where sets packaged for retail sale are involved is provided on the CBP website in
“CBP Section 301 Trade Remedies Frequently Asked Questions”. The answer to “How are the Section 301
duties assessed in respect to sets packaged for retail sale, which contain components covered by the Section
301 remedy,” reads, in pertinent parts, as follows:
When importing goods put up in sets for retail sale (in accordance with General Rule of Interpretation
3) that contain articles subject to the Section 301 remedy, if the product that imparts the essential
character to the set (i.e., the HTSUS provision under which the entire set is classified) is covered by
the Section 301 remedy, then the entire set will be subject to the additional duties.
If the HTSUS provision under which the entire set is classified is not covered by the Section 301
remedies, but the set contains components that are classified in a subheading covered by the 301 list,
the 301 duties will not be assessed on the individual components.
Following this guidance, the pliers are products of Vietnam and are classified within the tariff provision that
the complete set is classified. Accordingly, the country of origin of the jewelry making kit is Vietnam.
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 Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.69, in addition to subheading
8203.20.6030, 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 Anthony Grossi at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division