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NY N015243

August 14, 2007



TARIFF NO.: 7113.11.5000

Susan Byrne
Tiffany & Company
15 Sylvan Way
Parsippany, NJ 07054

RE: The tariff classification of silver necklace with pendant from Germany.

Dear Ms. Byrne:

In your letter dated August 3, 2007 you requested a tariff classification ruling.

The item submitted for classification is a women’s necklace. In China, a titanium cross and a sterling silver dog tag are created. The titanium cross weighs 0.40 grams. The sterling silver dog tag weighs 4.12 grams. These parts will be fabricated in China then shipped to Germany to be completed into the finished product. The parts will be polished, assembled, engraved, controlled and wrapped in Germany. The finished cross and dog tag, which create a pendant when displayed together, are then attached to a 925 chain with lobster clasp which is completely fabricated in Germany. Under the provisions of 19CFR102.11, although the metal parts undergo further processing in Germany, the metal parts of the cross and dog tags are a product of China and constitute the essential character of the item. Consequently, for purposes of marking and duty assessment, the country of origin is China.

The applicable subheading for the silver necklace will be 7113.11.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Articles of jewelry and parts thereof, of precious metal or of metal clad with precious metal: Of precious metal whether or not plated or clad with precious metal: Of silver, whether or not plated with other precious metal: Other: Other”. The rate of duty will be 5% ad valorem.

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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