The tariff classification of jewelry findings from China

N282548 February 9, 2017 CLA-2-73:OT:RR:NC:N1:113 CATEGORY: Classification TARIFF NO.: 7326.20.0071 Ms. Elizabeth McGuffin Dollar General Corporation 100 Mission Ridge Goodlettsville, TN 37072 RE: The tariff classification of jewelry findings from China Dear Ms. McGuffin: In your letter dated January 5, 2017, you requested a tariff classification ruling. A sample, marketing information and photographs of the subject jewelry findings were submitted for our review. The product under consideration is identified as jewelry findings, SKU Number 16587005. You stated that “One selling unit will contain 183 pieces of jewelry findings, to be used in making jewelry, such as a crafty necklace.” The items that comprise the jewelry findings kit under consideration include stainless steel headpins, metal alloy lobster clasps, copper crimp beads, iron earring hooks and stainless steel jump rings. All of the items that are included in the subject jewelry findings kit will be packaged together on a blister display card ready for retail sale prior to importation into the United States. The General Rules of Interpretation (GRIs) set forth the legal framework in which merchandise is to be classified under the Harmonized Tariff Schedule of the United States Annotated (HTSUS). GRI 1 requires that classification be determined first according to the terms of the headings of the tariff and any relative section or chapter notes. Goods that cannot be classified in accordance with GRI 1 are to be classified in accordance with subsequent GRIs taken in order. GRI 3(b) covers goods put up in sets for retail sale. Such goods: (a) consist of at least two different articles that are classifiable in different headings, (b) consist of products put up together to meet a particular need or carry out a specific activity, and (c) are put up in a manner suitable for sale directly to users without repacking. The jewelry findings kit in question, in our opinion, meets the criteria for sets as the terms are defined. Having determined that the subject items constitute a set for tariff classification purposes, we must decide the essential character for the set. Essential character may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of the constituent material in relation to the use of the goods. The jewelry findings kit under consideration includes articles made of stainless steel, copper and iron. In this case, we note that the stainless steel headpins and stainless steel jump rings are both classified under heading 7326, HTSUS, as other articles of steel. Based on our review of the Material List – 16587005, the stainless steel headpins predominate by weight and by value over each of the items in the jewelry findings set. Therefore, it is the opinion of this office that the stainless steel headpins impart the essential character for the set. In accordance with GRI 3(b), the jewelry findings set will be classified in subheading 7326.20, HTSUS, which provides for other articles of steel, articles of iron or steel wire. The applicable subheading for the jewelry findings, SKU Number 16587005, will be 7326.20.0071, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of iron or steel, articles of iron or steel wire, other. The rate of duty will be 3.9 percent ad valorem. 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 on World Wide Web at https://hts.usitc.gov/current. 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 Ann Taub at ann.taub@.cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division