The classification, origin, marking, and eligibility under subheading 9802.00.80 on jewelry

N356279 December 5, 2025 CLA-2:OT:RR:NC:N4:441 CATEGORY: Origin Shanshan Liang Liang + Mooney, PLLC 2104 Delta Way, Suite #1 Tallahassee, FL 32303 RE: The classification, origin, marking, and eligibility under subheading 9802.00.80 on jewelry Dear Ms. Liang: In your letter dated November 20, 2025, you requested a country of origin ruling on behalf of your client, Stellar Jewels, LLC. You submitted photographs, product description, and manufacturing information for our review. The subject merchandise is a gold rope chain necklace which is constructed of United States (U.S.) origin gold. The manufacturing steps are as follows: The gold is melted, cast, drawn, coiled, and cut in the United States. The U.S links are exported to Bolivia. The individual links are assembled including weaving, soldering, adding clasps and end rings, cleaning, and polishing in Bolivia. The applicable subheading for the gold necklace will be 7113.19.29, 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: Necklaces and neck chains, of gold: Other.” The general rate of duty will be 5.5% ad valorem. 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 jewelry is the United States. We agree. The casting of the links in the United States provides the essence of the finished product. Assembling the links does not substantially transform the castings. As a result, the country of origin of the necklace is the United States. Therefore, the finished necklace will be considered a product of the United States for marking purposes and for purposes of trade remedies. Since the country of origin will be the United States, the necklace 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. Your request also concerns the eligibility of the necklace under subheading 9802.00.80, HTSUS. Subheading 9802.00.80, HTSUS, provides a partial duty exemption for articles assembled abroad in whole or in part of fabricated components, the product of the United States, which (a) were exported in condition ready for assembly without further fabrication, (b) have not lost their physical identity in such articles by change in form, shape or otherwise, and (c) have not been advanced in value or improved in condition abroad except by being assembled and except by operations incidental to the assembly process, such as cleaning, lubricating and painting. All three requirements of subheading 9802.00.80, HTSUS, must be satisfied before a component may receive a duty allowance. We find the described foreign processing acceptable for the purposes of 9802.00.80, HTSUS. An article entered under this tariff provision is subject to duty upon the full cost or value of the imported assembled article, less the cost or value of the U.S. components assembled therein, upon compliance with the documentary requirements of section 10.24, Customs Regulations (19 CFR 10.24). 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. 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division