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NY N021355

January 16, 2008



TARIFF NO.: 7117.19.9000

Ms. Roseann Downing
Life is Good, Inc.
283 Newbury Street
Boston, MA 02115

RE: The tariff classification of imitation jewelry from China.

Dear Ms. Downing:

In your letter dated December 27, 2007, you requested a tariff classification ruling. The five samples which you submitted are being returned as requested.

Style number JJ-298 “Skyler Necklace” is comprised of a narrow 18 inch cotton strap with an inscribed zinc pendant and brass closure. Style number JJ348 “Gigi Anklet” has nine inch double strap made of leather. An inscribed zinc pendant is attached and it has a brass closure. Style number JJ354 “Gigi Bracelet” consists of an inscribed zinc pendant suspended from two 3 inch long nylon straps. This unit also has a brass closure. Style number JJ299 “Have a Heart Necklace” is comprised of a narrow 18 inch nylon strap holding a zinc heart-shaped pendant and brass closure. It has been determined that the metal pendants impart the essential character to these products.

Additional information is necessary before a classification decision can be made for style number JJ4105 “Lakewood Leather Key Chain.” Please provide a breakdown by weight for each different type of metal (i.e. zinc, brass, iron, steel, etc.) that comprises the key chain. Include all the metal components in the breakdown including the carabiner/snaphook, split wire keying and connector ring. If any metal portion of the item is an “alloy” of metals, identify the precise metals by name (steel, iron, copper, etc.). If you decide to resubmit your request, please include the material that we have returned to you and mail your request to U.S. Customs and Border Protection, Customs Information Exchange, 10th Floor, One Penn Plaza, New York, NY 10119, attn: Binding Rulings Section.

The applicable subheading for the necklaces, anklet and bracelet will be 7117.19.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other.” The rate of duty will be 11% 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 imitation jewelry ruling, contact National Import Specialist Larry Mushinske at 646-733-3036. If you have any questions regarding the key chain ruling, contact Ann Taub at 646-733-3018.


Robert B. Swierupski

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