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NY 875197

June 19, 1992

CLA-2-:71:S:N:N3G:344 875197


TARIFF NO.: 7113.11.2000; 7113.11.5000

Mr. Kevin M. Diran, President
Armen Cargo Services
P.O. Box 280668
San Francisco, CA 94128

RE: The tariff classification of sterling silver earrings from Thailand.

Dear Mr. Diran:

In your letter of June 3, 1992, on behalf of Tomas Jewelry, Arcata, California, you requested a tariff classification ruling on sterling silver earrings from Thailand.

You have requested a definition of the term "piece" as it applies to a pair of earrings imported on a card and earrings imported in bulk and carded in the United States. In effect, you are asking for an interpretation of the phrase "per dozen pieces" as it appears in subheading 7113.11.2000, Harmonized Tariff Schedule of the United States (HTS).

You have asked if the removable clutch backs are considered "pieces" for tariff purposes and therefore dutiable.

You also present a second situation in which earrings are imported in bulk form and carded in the United States utilizing local labor.

In both situations, an earring, whether or not attached to a clutch back, is considered one "piece." Therefore, a pair of earrings is two "pieces."

Sterling silver earrings valued not over $18 per dozen pieces, with or without clutch backs (not over $1.50 per single earring) are dutiable at 27.5% in subheading 7113.11.2000, HTS. Sterling silver earrings valued over $18 per dozen pieces, with or without clutch backs (over $1.50 per single earring) are dutiable at 6.5% in subheading 7113.11.5000, HTS.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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