THE COUNTRY OF ORIGIN MARKING OF JEWELRY FROM ST. CROIX, U.S. VIRGIN ISLANDS

NY L87510 September 19, 2005 MAR-2 RR:NC:SP:233 L87510 CATEGORY: MARKING Mr. C.J. Erickson Cowan, Liebowitz & Latman, P.C. 1133 Avenue of the Americas New York, NY 10036-6799 RE: THE COUNTRY OF ORIGIN MARKING OF JEWELRY FROM ST. CROIX, U.S. VIRGIN ISLANDS Dear Mr. Erickson: In your letter dated September 6, 2005, on behalf of Leach & Garner, you requested a tariff classification ruling. Your letter concerns four situations regarding U.S. origin gold jewelry items sent to St. Croix, U.S. Virgin Islands. The first concerns Ball Earrings. A gold pin of U.S. origin is sent to St. Croix. The pin is manufactured in the U.S. from raw material wire. A gold setting of U.S. origin is sent to St. Croix. The setting is blanked in the U.S. from raw material gold sheet. A gold ball of U.S. origin is sent to St. Croix. The ball is blanked in the U.S. from raw material sheet gold and further processed through a series of forming, coning and rolling operations. The three components are assembled and treated with gold solder paste. The entire ball earring is manually loaded into a coal furnace to complete the soldering process. The finished earrings are cleaned, polished, deburred, marked and packaged. The second concerns Lightweight Cups. Gold pins of U.S. origin are sent to St. Croix. The pin is manufactured in the U.S. from raw material wire. Gold settings of U.S. origin are sent to St. Croix. The setting is blanked in the U.S. from raw material gold sheet. The two components are assembled and treated with gold solder paste. The entire piece is manually loaded into a coal furnace to complete the soldering process. The finished earrings are cleaned, polished, deburred, marked and packaged. The third item concerns Diamond Settings on a Pin. A gold pin of U.S. origin is sent to St. Croix. The pin is manufactured in the U.S. from raw material wire. A gold setting of U.S. origin is sent to St. Croix. The setting is blanked in the U.S. from raw material gold sheet. The two components are assembled and treated with gold solder paste. The entire piece is manually loaded into a coal furnace to complete the soldering process. The finished earrings are cleaned, polished, deburred, marked and packaged. The fourth item concerns Hoop Earrings. Gold hoop frames of U.S. origin are sent to St. Croix. The cut ends of each hoop frame are somewhat distorted due to the cutting and gapping operations performed in the United States. The hoop frames are not in a condition ready for assembly into finished earrings. A gold top wire assembly of U.S. origin is sent to St. Croix. The tubes are re-sized manually in St. Croix through the use of a mechanical tool to re-form each tube end. This procedure is necessary to create the desired shape on which the end cap is placed prior to the furnace solder operation. The hoop frame, end caps and top wire assembly are placed in a coal furnace and soldered to produce a semi-finished hoop earring. The finished pieces are cleaned, polished, deburred, marked and packaged for delivery to the United States. In all four situations, the parts or components have been substantially transformed into articles of jewelry. They have a different name, character, use and classification. The jewelry items are considered a product of St. Croix for marking purposes. Noting 19 CFR 134.32 (L) products of possessions of the U.S. are exempt from country of origin marking. As per 19 CFR 134.22, the outermost container must be marked to indicate the country of origin. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Lawrence Mushinske at 646-733-3036. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division