N354828

N354828 November 3, 2025 CLA-2-71:OT:RR:NC:N4:441 CATEGORY: Origin; Marking David Murphy GDLSK 599 Lexington Avenue, 36th Floor New York, NY 10022 RE: The tariff classification and eligibility under subheading 9802.00.5060 on gold jewelry. Dear Mr. Murphy: In your letter dated October 8, 2025, you requested a ruling on behalf of your client, D. N. Jewels USA Inc. You submitted photographs, product description, and manufacturing information on gold jewelry for our review. Style UXSDR 4485 is a 14K yellow gold ring set diamonds. Style UXSDR 4486 is a 14K yellow gold ring set with diamonds. Style UXSDR 4481 is a 14K gold white ring set with diamonds. Style UXDR 12612 is a 14K gold yellow ring set with diamonds. Style UXDR 12614 is a 14K white gold ring set with diamonds. The manufacturing steps performed in the United States are as follows: Product designed Wax model created Alloying and metal casting Spruing, investing, and wax burnout performed Cooling and mold break-out Sprue cutting Casting export The manufacturing steps performed in India are as follows: Gems are set Polish and buffing think coating of rhodium applied Logo engraving Packaging The applicable subheading for Styles UXSDR 4485, UXSDR 4486, UXSDR 4481, UXDR 12612 and UXDR 12614 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. Your request also concerns the eligibility of the jewelry under subheading 9802.00.5060, HTSUS. Subheading 9802.00.5060, HTSUS, provides a partial or complete duty exemption for articles returned to the U.S. after having been exported to be advanced in value or improved in condition by any process of manufacture or other means, provided that the documentary requirements of Section 10, Customs Regulations (19 CFR 10.8) are satisfied. Pursuant to 19 CFR 10.8, the importer must submit a declaration executed by the person who performed the repairs or alterations and a declaration of his own containing various attestations. Articles eligible under subheading 9802.00.5060 are subject to duty upon the value of the repairs, alterations, processing, or otherwise changes in condition abroad, pursuant to Note 3 to Subchapter II, Chapter 98, HTSUS. We find the described foreign processing acceptable for the purpose of subheading 9802.00.5060, HTSUS. Accordingly, upon reimportation, the gold diamond rings will be eligible for tariff treatment under 9802.00.5060, HTSUS, provided the documentary requirements of 19 CFR 10.8 are satisfied. You have also inquired about the country of origin of the above-described jewelry. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. U.S., 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. U.S., 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). You proposed that the country of origin of the jewelry is the United States. We agree. The casting of the gold jewelry in the United States 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 the bracelet is the United States. Therefore, the finished jewelry will be considered a product of the United States for marking purposes and for purposes of trade remedies. Since the country of origin will be the United States, the gold diamond earrings, bracelet and rings will be excepted from country of origin marking requirements and will not be subject to additional trade remedy measures, such as reciprocal or global tariffs. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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

is applicable. See, e.g., Headquarters Ruling Letter (HQ) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. U.S., 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. U.S., 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). You proposed that the country of origin of the jewelry is the United States. We agree. The casting of the gold jewelry in the United States 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 the bracelet is the United States. Therefore, the finished jewelry will be considered a product of the United States for marking purposes and for purposes of trade remedies. Since the country of origin will be the United States, the gold diamond earrings, bracelet and rings will be excepted from country of origin marking requirements and will not be subject to additional trade remedy measures, such as reciprocal or global tariffs. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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