THE COUNTRY OF ORIGIN MARKING OF A 14 KT YELLOW GOLD AND PEARL NECKLACE

NY L87655 September 22, 2005 MAR-2 RR:NC:SP:233 L87655 CATEGORY: MARKING Ms. Susan Byrne Tiffany & Co. 15 Sylvan Way Parsippany, NJ 07054-3893 RE: THE COUNTRY OF ORIGIN MARKING OF A 14 KT YELLOW GOLD AND PEARL NECKLACE Dear Ms. Byrne: This is in response to your letter dated September 13, 2005 requesting a ruling on the proper country of origin marking for a 14kt yellow gold and pearl necklace. A gold chain and clasp are made in Italy. The completed necklace is sent to China. China glues 9 freshwater pearls onto the necklace and the finished good is shipped from China to the U.S. You have submitted a picture of the finished item and a breakdown of the gram weight and labor cost per price for each component of the process. In your submitted weight and labor breakdown, the majority of the labor is performed in Italy. In China, there is no substantial transformation, only completion of the item. Thus, the necklace is considered a product of Italy and must be marked accordingly. The applicable subheading for the 14 KT yellow gold and pearl necklace will be 7113.19.5000, HTS, which provides for “Articles of jewelry and parts thereof, of precious metal or of metal clad with precious metal: Of precious metal whether or not plated or clad with precious metal… Other:” The rate of duty will be 5.5% ad valorem. 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