The classification, origin, marking, and eligibility under subheading 9802.00.5060 on jewelry

N354862
November 3, 2025
OT:RR:NC:N4:441
CATEGORY: Origin Brennan O'Gorman Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP 599 Lexington Avenue, Floor 36 New York, NY 10022 RE: The classification, origin, marking, and eligibility under subheading 9802.00.5060 on jewelry Dear Mr. O'Gorman: In your letter dated October 10, 2025, you requested a country of origin ruling on behalf of your client, Richline Group. You submitted photographs, product description, and manufacturing information on gold jewelry. Style DA9352 is a gold bracelet set with diamonds. STEPS PERFORMED IN THE U.S. 1. Wax impressions of the individual bracelet components are assembled onto a wax rod to form a tree. 2. The wax trees are placed into steel flasks and filled with plaster casting investment. 3. The flasks are placed in an oven which melts out the wax, leaving a plaster mold. 4. Fine gold and alloy metals are melted together to create a 14-karat casting grain. 5. The casting grain is re-melted and injected into the plaster molds. 6. After cooling, the plaster is broken away, leaving a gold version of the original wax tree. 7. The individual bracelet components are cut from the tree, inspected for quality, and packed for shipment. MANUFACTURING STEPS PERFORMED ABROAD 1. Upon receipt in China, Thailand, India, or Vietnam, the individual links and clasp components are filed to remove excess metal. 2. The components are pre-polished in a vibratory tumbler. 3. The individual components are assembled with a laser welding machine. 4. Diamonds are set into individual links using small hand tools and drills. 5. The bracelets receive a final polish and are plated with rhodium. 6. Each piece is inspected for quality and packaged for export back to the United States.

The applicable subheading for the bracelet will be 7113.19.50, 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: Other.” The general rate of duty will be 5.5% ad valorem. Your request also concerns the eligibility of the bracelet under subheading 9802.00.5060, HTSUS. Subheading 9802.00.5060, HTSUS, provides a partial or complete duty exemption for articles returned to the U.S. after having been exported to be advanced in value or improved in condition by any process of manufacture or other means, provided that the documentary requirements of Section 10, Customs Regulations (19 CFR 10.8) are satisfied. Pursuant to 19 CFR 10.8, the importer must submit a declaration executed by the person who performed the repairs or alterations and a declaration of his own containing various attestations. Articles eligible under subheading 9802.00.5060 are subject to duty upon the value of the repairs, alterations, processing, or otherwise changes in condition abroad, pursuant to Note 3 to Subchapter II, Chapter 98, HTSUS. We find the described foreign processing acceptable for the purposes of 9802.00.5060, HTSUS. Accordingly, upon reimportation, the bracelet will be eligible for tariff treatment under 9802.00.5060, HTSUS, provided the documentary requirements of 19 CFR 10.8 are satisfied. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. U.S., 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. U.S., 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). You propose that the country of origin of subject bracelet is the United States. We agree. The casting of the jewelry in the United States provides the essence of the finished product. Setting the gems, connecting the links, and performing final finishing does not substantially transform the castings. As a result, the country of origin of the bracelet is the United States. Therefore, the finished bracelet will be considered products of the United States for marking purposes and for purposes of trade remedies. Since the country of origin will be the United States, the bracelet will be excepted from country of origin marking requirements and will not be subject to additional trade remedy measures, such as reciprocal or global tariffs. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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].

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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division