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NY N023308

February 25, 2008



TARIFF NO.: 7117.11.0000

Ms. Sarah Schaeffer
Three Boxes
60 James Street
Charlestown 2290

RE: The tariff classification of cuff links from China.

Dear Ms. Schaeffer:

In your letter dated February 12, 2008, you requested a tariff classification ruling.

The items to be classified are cuff links made of alloy and chrome. Each of the cuff links will weigh approximately 2.24 ounces and are designed in two styles, with either a dice or poker hand motif. The cuff links after importation will be distributed as gifts at a sales conference.

The applicable subheading for the cufflinks will be 7117.11.0000 Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Imitation jewelry: Of base metal, whether or not plated with precious metal: Cuff links and studs.” The rate of duty will be 8% ad valorem.

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. Section 134.1(d) of the Customs Regulations defines the ultimate purchaser as generally the last person in the U.S. who will receive the article in the form in which it was imported; 134.1(d) (4) further states that if an imported article is distributed as a gift, the recipient is the ultimate purchaser. 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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