N354611

N354611 October 28, 2025 CLA-2-71:OT:RR:NC:N4:441 CATEGORY: Classification; Origin Michele Lehat, Esq. Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP 599 Lexington Ave, 36th Floor New York, NY 10022 TARIFF NO.: 7113.19.50; 7113.11.50; 9903.01.25 RE: The tariff classification and country of origin on jewelry from the United Arab Emirates (UAE). Dear Ms. Lehat: In your letter dated October 3, 2025, you requested a ruling on behalf of your client, Jewelex New York Ltd. and Zenstar Jewelry LLC. You submitted photographs, product description, and manufacturing information on several styles of jewelry for our review. Style JNX6293 is a pair of gold earrings set with diamonds. Style JNB7287SK is a gold ring set with diamonds. The applicable subheading for styles JNX6293 and JNB7287SK, of gold or platinum, will be 7113.19.50, 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 other precious metal, whether or not plated or clad with precious metal. The general rate of duty will be 5.5% ad valorem. The applicable subheading for styles JNX6293 and JNB7287SK, of silver, will be 7113.11.50, 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 or clad with other precious metal: Other: Other.” The rate of duty will general be 5% ad valorem. You have indicated that the earrings (style JNX6293) will be produced from castings made in the UAE, which are then sent to India for assembly into finished articles. The production steps are as follows: Step 1: Design – Performed in India. Step 2: Wax/Resin Model – Performed in India. Step 3: Metal Casting – Performed in the UAE. Step 4: Sprue Removal – Performed in the UAE. Step 5: Filing and Finishing – Performed in the UAE. Step 6: Assembly – Performed in India. Multiple parts of the earrings are soldered together. Step 7: Stone Setting – Performed in India. Step 8: Final Polishing – Performed in India. The earrings are polished to achieve their finished appearance. The ring (style no. JNB7287SK) will be produced from castings made in the UAE, which are then sent to India for assembly into finished articles. The manufacturing steps are as follows: Step 1: Design – Performed in India. Step 2: Wax/Resin Model – Performed in India. Step 3: Metal Casting – Performed in the UAE. Step 4: Sprue Removal – Performed in the UAE. Step 5: Filing and Finishing – Performed in the UAE. Step 6: Stone Setting – Performed in India. Step 7: Final Polishing – Performed in India. You proposed that the country of origin of the jewelry is United Arab Emirates. We agree. The casting of the jewelry in the UAE provides the essence of the finished products. Setting the gems and performing final finishing does not substantially transform the castings. As a result, the country of origin of jewelry is UAE. Therefore, the finished jewelry will be considered a product of the UAE for marking purposes and for purposes of trade remedies. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of United Arab Emirates will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 7113.19.50 and 7113.11.50 HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Vikki Lazaro at vikki.lazaro@cbp.dhs.gov. 
Sincerely,
 (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division