The classification and country of origin of a gold bracelet

N359868 April 6, 2026 OT:RR:NC:CEE008:N4:441 CATEGORY: Origin Megan Zebrowski Kendra Scott LLC 3800 N Lamar Blvd, 400 Austin, TX 78756 RE: The classification and country of origin of a gold bracelet Dear Ms. Zebrowski: In your letter dated March 19, 2026, you requested a classification and country of origin ruling on a gold bracelet. You have submitted photographs and descriptive literature for our consideration. Style 9608803241 is a gold chain bracelet set with diamonds. The manufacturing steps in India are as follows: Diamonds are sourced and set The chain links of the bracelet are cast (i.e., formed from metal into the shape of the links). All components are assembled into the finished bracelet. The manufacturing steps in the United States are as follows: Eleven decorative components and the logo tag are cast. The applicable subheading for the gold bracelet 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. 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. United States, 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. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. The casting of the links of the bracelet in India is the operation that results in a substantial transformation, as it imparts the essential character to the article and results in a product with a new name, character, and use distinct from that of the components exported from the United States. Subsequent operations, including the setting of the diamonds and assembly of the components into the finished bracelet, are ancillary and do not constitute substantial transformation. As such, the country of origin of the finished bracelet is India. In NY N271751, dated January 14, 2016, CBP ruled that a single “substantial transformation” occurred when a ring was cast, with all subsequent processes, including the mounting of diamonds, representing ancillary, non-substantial operations. You have also inquired as to whether this product qualifies for treatment as an American good returned. The merchandise does not qualify for duty-free treatment under subheading 9801.00.10, HTSUS, as the exported U.S.-origin components were advanced in value and improved in condition while abroad and were transformed into a new and different article of commerce. Moreover, the foreign processing does not constitute repairs or alterations within the meaning of subheading 9802, HTSUS, but rather results in the manufacture of a finished article, thereby precluding eligibility under that provision. 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) James P. Forkan Director National Commodity Specialist Division