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

NY L87990 October 13, 2005 MAR-2 RR:NC:SP:233 L87990 CATEGORY: MARKING Mr. C.J. Erickson Cowan, Leibowitz & 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 27, 2005, on behalf of Leach & Garner, you requested a marking ruling. Your letter concerns the proper country of origin marking for U.S. origin jewelry parts sent to St. Croix, U.S. Virgin Islands for manufacture into gold top wire assemblies. The specific manufacturing steps include the following: Raw material gold sheet stock of U.S. origin is sent to St. Croix. A joint is blanked and formed through the use of a power press. Specific length gold wire of U.S. origin is sent to St. Croix. A U.S. origin rivet is inserted through the joint opening and one end of the gold wire. The end of the rivet is flattened to secure the joint to the wire forming the top wire assembly. The finished pieces are cleaned, polished and packaged. The jewelry parts sent to St. Croix have been substantially transformed into a new article of commerce. The wire assemblies have a different name, character, use and classification. The wire assemblies 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 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, contact National Import Specialist Lawrence Mushinske at 646-733-3036. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division