CLA-2-74: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 fashion belts from China
Dear Ms. Yanes:
In your letter dated December 12, 2025, you requested a tariff classification ruling regarding fashion belts
from China. Product information was submitted with your request.
The items under consideration are two styles of fashion belts (Styles CAP26.01-1 and CAP26.01-2) primarily
used to wear over clothing. At importation, both belts will consist of five connected “layers” of brass chain
plated with 14-karat gold. You clarify that the first layer of both styles will include one cubic zirconia stone.
Additionally, style CAP26.01-1 will feature an included charm composed of brass with ivory mother of pearl.
Style CAP26.01-2 will feature an included charm composed of brass with Drusy stones. You state that after
importation, the layers of brass chain and the associated charms may be detached from the singular belt for
customization and use as standalone articles.
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 belts 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 14-karat gold plated brass layers impart the essential character to the fashion belts because
they provide the primary structure to be worn over clothing as desired. The brass layers also facilitate
connection to each other and to the companion charms. Furthermore, their gold plating imparts significant
decorative appeal. In accordance with GRI 3(b) and GRI 6, the fashion belts under consideration will be
classified as an other article of copper.
The applicable subheading for the fashion belts (Styles CAP26.01-1 and CAP26.01-2) will be 7419.80.3000,
HTSUS, which provides for “Other articles of copper: Other: Other: Coated or plated with precious metal.”
The general rate of duty will be 3 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