CLA-2-73:OT:RR:NC:CEE008:N1:164
Tabbatha Yanes
Kendra Scott LLC
3800 North Lamar Blvd., Suite 400
Austin, TX 78756
RE: The tariff classification of a wristlet strap from Cambodia
Dear Ms. Yanes:
In your letter dated December 3, 2025, you requested a tariff classification ruling regarding a wristlet strap
from Cambodia. Product information was submitted with your request.
The item under consideration is described as a star wristlet strap for attachment to wristlet purses as a
functional yet decorative item. The wristlet strap consists of five connected components: a star-shaped zinc
clip, a small zinc charm, an iron O-ring, an iron chain, and a colored polyester paracord which is braided
through the iron chain. The star-shaped zinc clip allows for attachment to wristlet purses and connects to the
iron chain by the O-ring. The charm is also attached to the O-ring and dangles freely. You state that the four
metal components are coated with brass alloy. Based on the information provided, the iron chain is the
dominant component by weight and value. The wristlet strap will be imported in seven different colors.
Classification of merchandise under the Harmonized Tariff Schedule of the United States (HTSUS) is in
accordance with the General Rules of Interpretation (GRIs), taken in order. GRI 1 provides that classification
shall be determined according to the terms of the headings and any relative section or chapter notes. Since no
one heading in the tariff schedules covers the components of the star wristlet strap in combination, GRI 1
cannot be used as a basis for classification. GRI 3(b) provides that mixtures, composite goods consisting of
different materials or made up of different components, and goods put up in sets for retail sale shall be
classified as if they consisted of the material or component which gives them their essential character.
As the star wristlet strap is a composite good, we must apply rule GRI 3(b), which provides that composite
goods are to be classified according to the component that gives the goods their essential character.
Explanatory Note (EN) VIII to GRI 3(b) explains that “the factor which determines essential character will
vary as between different kinds of goods. It may, for example, be determined by the nature of the material or
component, its bulk, quantity, weight or the use of the goods.” We must determine which component imparts
the essential character to the key ring in question. It is the role of the constituent materials or components in
relation to the use of the good that imparts the essential character.
In this case, the totality of the metal components imparts the essential character to the star wristlet strap.
Specifically, the zinc clip, iron O-ring, and iron chain provide the primary structure for a user to hold and
carry an attached wristlet purse. The metal components also impart significant decorative appeal. Therefore,
it is the opinion of this office that the metal components impart the essential character to the key ring. In
accordance with GRI 3(b), the star wristlet strap under consideration will be classified as an other article of
metal.
Section XV, Note 7 of the HTSUS states that the classification of composite articles of base metal containing
two or more base metals are to be treated as articles of the base metal that predominates by weight over each
of the other metals. Based on the information provided to our office, the metal in the subject key ring that
predominates by weight is iron. Therefore, the article in question is classifiable in heading 7326, HTSUS,
which provides for other articles of iron or steel.
The applicable subheading for the star wristlet strap will be 7326.90.8688, HTSUS, which provides for
“Other articles of iron or steel: Other: Other: Other: Other: Other.” The general rate of duty will be 2.9
percent ad valorem.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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
(C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division