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

N355200 November 7, 2025 OT:RR:NC:N4:441 CATEGORY: Origin Laura Moya Nakachi Eckhardt & Jacobson, P.C. 50 California Street San Francisco, CA 94111 RE: The classification, origin, marking, and eligibility under subheading 9802.00.5060 on bracelets Dear Ms. Moya: In your letter dated October 24, 2025, you requested a ruling on behalf of your client, Sunrise Jewelry Manufacturing Corporation. You submitted photographs, product description, and manufacturing information on gold bracelets. Item number BB 131-S 14k is white gold stretch bracelets set with diamonds. Item number BB77-S is a 14k white gold stretch bracelet castings/mounting without diamonds. Manufacturing Steps: Creating the wax model. This is performed in Mexico. Metal casting. This is performed in the United States. Assembling bracelet links. This is performed in Mexico. Setting the diamonds (Item number BB 131-S only). This is performed in Mexico. Final finishing. This is performed in Mexico. The applicable subheading for the bracelets with or without diamonds 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 bracelets 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 bracelets 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 bracelets is the United States. We agree. The casting of the bracelets in the United States provides the essence of the finished products. Setting the gems, assembling the links, and performing final finishing does not substantially transform the castings. As a result, the country of origin of the bracelets is the United States. Therefore, the finished bracelets 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 jewelry 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 vikki.lazaro@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division