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NY N005929

January 30, 2007



TARIFF NO.: 7117.90.7500

Ms. Veronica J. Miller
Liz Claiborne, Inc.
One Claiborne Avenue
North Bergen, NJ 07047

RE: The tariff classification of a set of three ladies’ bracelets from China.

Dear Ms. Miller:

In your letter dated January 22, 2007, you requested a tariff classification ruling.

The submitted sample is identified as a set of three (3) ladies’ bracelets, Style #OJRU1174. Bracelet #1 is composed of glass and base metal beads, bracelet #2 is composed of plastic beads, and bracelet #3 is composed of semiprecious (calcite, jade), glass and base metal beads. All three bracelets are constructed by having the beads strung on textile elastic cord. The bracelets are joined by a small base metal connector chain with a spring ring clasp. The three bracelets will be shipped, packaged and sold together at retail as a set. They are intended to be worn together. You have also submitted digital photos of and cost and weight breakdowns for the subject bracelets with your request.

The Explanatory Notes to the Harmonized Tariff System provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. Explanatory Note X to GRI 3(b) provides that the term “goods put up in sets for retail sale” means goods that: (a) consist of at least two 2 different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking. GRI 3 (a) states in part when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarded as equally specific, even if one heading gives a more precise description of the good. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. GRI 3(c) provides that when goods cannot be classified by reference to GRI 3(a) or 3(b), they are to be classified in the heading that occurs last in numerical order among those which equally merit consideration.

The set of three ladies’ bracelets, Style #OJRU1174, is considered to be a set for tariff classification purposes. No single component imparts the essential character, so the set will be classified in accordance with GRI 3(c). In this set, the heading for bracelet #2, composed of plastic beads, appears last in numerical order among the competing headings which equally merit consideration. Bracelet #2 is valued at over 20 cents per dozen pieces or parts.

Your sample is being returned as requested.

The applicable subheading for the set of three ladies’ bracelets, Style #OJRU1174, will be 7117.90.7500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Of plastics.” The rate of duty will be Free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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


Robert B. Swierupski

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