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NY L81867




January 18, 2005

MAR-2 RR:NC:SP:233 L81867

CATEGORY: MARKING

Ms. Susan Studeny
Tiffany & Co.
15 Sylvan Way
Parsippany, NJ 07054-3893

RE: THE COUNTRY OF ORIGIN MARKING OF NECKLACES AND BRACELETS.

Dear Ms. Studeny:

This is in response to your letter dated December 24, 2004, on behalf of Tiffany & Co., requesting a ruling on the proper country of origin marking on three types of “scarf” necklaces and bracelets. Each necklace and bracelet will be made of both 18kt yellow gold and 18kt white gold.

A raw mesh zig zag scarf necklace, made to specific lengths in Japan, will be imported into Germany. A round stamping plate with Tiffany’s logo will be made in Germany. The following labor will be performed in Germany: quality controls on all soldering points on the mesh, laser solder all weak sections by hand, polish the mesh, stamp out the stamping tag, laser engrave the stamping tags, and laser the stamping tag on the mesh.

You have submitted a weight and labor breakdown. The scarf necklace is an unfinished necklace when imported into Germany from Japan. At that time it includes the majority of the weight and labor costs. In Germany there is no substantial transformation, only completion of the item. Thus, it is considered a product of Japan and must be marked accordingly.

Similar scenarios apply to the zig zag bracelet, scallop scarf necklace and bracelet and lace scarf necklace and bracelet. They must all be marked “Made in Japan.”

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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.

Sincerely,

Robert B. Swierupski
Director,

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