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HQ 088414

February 12, 1991

CLA-2 CO:R:C:G 088414 NLP


TARIFF NO.: 7117.90.50; 6702.90.60; 4203.30.00

Ms. Agata M. Nowakowska
29W405 White Oak Drive
Warrenville, IL 60555

RE: Leather Jewelry

Dear Ms. Nowakowska,

This is in response to your letter dated December 13, 1990, requesting the tariff classification of leather jewelry and leather belts under the Harmonized Tariff Schedule of the United States (HTSUSA). You enclosed with your letter a sample of a leather necklace, a leather bracelet and a leather brooch. A sample of the leather belt was not submitted.


The leather necklace is composed of a V-shaped cardboard base, measuring approximately 5-3/4 inches on each side and 2 inches wide at the "V". Strips of leather are glued over the cardboard base. The back of the necklace is covered with a man- made textile fabric that has been glued on. A textile cord is attached to each end of the necklace. Each end of the cord is finished with strips of glued on leather. A decorative base metal fitting has been applied to the tip of the "V".

The leather bracelet is composed of a cardboard base covered with glued on strips of leather. The inside of the bracelet is finished off with a strip of glued on man-made textile fabric. The bracelet, which has no clasp, slips onto the wrist and measures approximately 1-1/8 of an inch in width.

The leather brooch is a representation of an artificial flower consisting of shaped and colorfully painted leather strips. The leather components are laced with a leather strip that is knotted at one end to secure parts in a floral bloom configuration. A metal fastening pin is secured to the article so that it can be attached to a garment.


What is the tariff classification of the leather necklace, bracelet, pin and belt?


Classification of merchandise under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1 provides that classification shall be determined first in accordance with the terms of the headings of the tariff and any relative section or chapter notes.

Heading 7117, HTSUSA, provides for imitation jewelry. Legal Note 10 to Chapter 71, HTSUSA, states that "[f]or the purposes of heading 7117, the expression 'imitation jewelry' means articles of jewelry within the meaning of paragraph (a) of note 8 above...." Legal Note 8(a) defines "articles of jewelry" as follows: "Any small objects of personal adornment (gem-set or not) (for example, rings, bracelets, necklaces, brooches, earrings, watch chains, fobs, pendants, tie pins, cuff links, dress studs, religious or other medals and insignia)...." The leather necklace and bracelet would be considered articles of jewelry and would be classifiable in Heading 7117, HTSUSA.

Heading 6702, HTSUSA, provides for artificial flowers, foliage and fruit and parts thereof; articles made of artificial flowers, foliage or fruit. The Explanatory Notes to Heading 6702, HTSUSA, provide that artificial flowers can be made of leather. In addition, the Explanatory Notes state that "[t]he heading includes artificial flowers, foliage or fruit fitted with a pin or other minor fastening device." Therefore, since the instant pin is designed as an artificial flower and has a pin attached, it would be classifiable in Heading 6702, HTSUSA, not Heading 7117, HTSUSA.

The leather belts would be classifiable in subheading 4203.30.00, HTSUSA, which provides for belts and bandoliers with without buckles, of leather or composition leather.


The leather necklace and bracelet are classifiable in subheading 7117.90.50, HTSUSA, which provides for imitation jewelry, other, other, valued over 20 cents per dozen pieces or parts. The rate of duty is 11 percent ad valorem.

The leather flower pin would be classifiable in subheading 6702.90.60, HTSUSA, which provides for articles made of artificial flowers... of other materials, other, other. The rate of duty is 17 percent ad valorem.
The leather belt would be classifiable in subheading 4203.30.00, HTSUSA, which provides for belts and bandoliers with without buckles, of leather or composition leather. The rate of duty is 5.3 percent ad valorem.


John Durant, Director
Commercial Rulings Division

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