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NY R03539

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March 31, 2006

MAR-2 RR:NC:SP:233 R03539

CATEGORY: MARKING

Ms. Susan Byrne
Tiffany & Co.
15 Sylvan Way
Parsippany, NJ 07054

RE: THE COUNTRY OF ORIGIN MARKING OF A LEATHER CORD NECKLACE WITH PENDANT

Dear Ms. Byrne:

This is in response to your letter dated March 24, 2006 requesting a ruling on the proper country of origin marking for a leather cord necklace when an American made pendant is attached in the U.S.

In Germany a lobster clasp assembly is glued to a leather cord and the necklace is then exported to the U.S. A pendant that is cast, polished and finished in the U.S. is then attached in the U.S.

You have submitted a value breakdown. Not only is the majority of the value in the leather cord necklace, when imported into the U.S. the item is classified as an article of jewelry. The addition of the pendant does not create a substantial transformation. Thus it is still considered a product of Germany and must be marked accordingly.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Lawrence Mushinske at 646-733-3036.

Sincerely,

Robert B. Swierupski
Director,

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