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HQ 953167

February 3, 1993

CLA-2 CO:R:C:M 953167 LTO


TARIFF NO.: 7117.19.50

Mr. Pentti Tervola
Rare Products
3663 Lakewood Road
Lake Worth, Florida 33461

RE: "Ringtool"; imitation jewelry; Chapter 71, Note 8(a), 10; GRI 2(a)

Dear Mr. Tervola:

This is in response to your letter of November 21, 1992, to Customs in Miami, Florida, requesting the classification of the "Ringtool" under the Harmonized Tariff Schedule of the United States (HTSUS). Your letter was referred to this office for a response.


The article in question is called the "Ringtool," a stainless steel finger ring. The ring has a magnet at the top center, the tips of a Phillips head screwdriver and flat head screwdriver on either side, and a claw or line/thread cutter at the bottom. You indicate that the ring has over 101 uses. You have submitted samples of a "raw casted" ring and a finished ring.


Whether the Ringtool is classifiable as imitation jewelry under Heading 7117, HTSUS.


The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states in pertinent part that "for legal purposes, classification
shall be determined according to the terms of the headings and any relative section or chapter notes . . . ." Heading 7117, HTSUS, provides for "[i]mitation jewelry."

Note 8(a) to Chapter 71 states that the expression articles of jewelry means "[a]ny small objects of personal adornment (gem- set or not) (for example, rings . . .)." Note 10 to Chapter 71 states that the expression imitation jewelry means "articles of jewelry within the meaning of paragraph (a) of Note 8 above . . ., not incorporating natural or cultured pearls, precious or semiprecious stones (natural, synthetic or reconstructed) nor (except as plating or as minor constituents) precious metal or metal clad with precious metal."

The Ringtool is an "article of jewelry" according to the above chapter note. Further, because it does not incorporate pearls, precious or semiprecious stones, nor precious metal or metal clad with precious metal, the Ringtool is an article of "imitation jewelry."

GRI 2(a) states that "[a]ny reference to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article." The "raw casted" ring, which has the exact shape of the finished ring, only must be polished to form the finished product. The unfinished ring has the essential character of the finished article, and therefore, both are classifiable under the same provision.


The Ringtool is classifiable under subheading 7117.19.50, HTSUS, which provides for "[i]mitation jewelry . . . [o]f base metal, whether or not plated with precious metal . . . [o]ther . . . [o]ther." The corresponding rate of duty for articles of this subheading is 11% ad valorem.


John Durant, Director

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