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NY L83008

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February 23, 2005

MAR-2 RR:NC:SP:233 L83008

CATEGORY: MARKING

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

RE: THE COUNTRY OF ORIGIN MARKING OF A BRACELET.

Dear Ms. Studeny:

This is in response to your letter dated February 10, 2005 requesting a ruling on the proper country of origin marking on a “Dangle” bracelet.

Round links and dangle charms made of silver are fabricated in Malaysia; these raw components are assembled into raw unpolished chain by the meter. The raw chain by the meter is sent from Malaysia to Germany. In Germany, it is machine polished and cut to lengths, findings are soldered in place, the Tiffany logo is laser engraved, and the piece is polished to completion and quality controlled. You have submitted a picture of the finished item and a spreadsheet with the breakdown of the gram weight and labor cost per piece for each process described above.

In your submitted weight and labor breakdown, the majority of the labor is performed in Malaysia. In Germany, there is no substantial transformation, only completion of the item. Thus, it is considered a product of Malaysia and must be marked accordingly.

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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