WEBVTT 00:00:00.000 --> 00:00:11.980 Welcome everyone. My name is Sandy Sary, and I'm a national import specialist responsible for jewelry and writing instruments. And today I will be discussing two headquarters rulings on jewelry. 00:00:14.080 --> 00:00:35.330 Before I discuss, those rulings are here is the CBP mission statement as well as the Office of Trade mission statement, the Office of Trade facilitates a legitimate trade and forces US laws and protects the American economy to ensure consumer safety and to create a level playing field for American businesses. 00:00:37.620 --> 00:00:51.560 Next, the first of two disclaimers, this webinar is for informational purposes only and reliance solely on the general information contained in this webinar may not be considered reasonable care. 00:04:06.780 --> 00:04:38.770 Now I wanna make sure that you all are not napping. Especially all the East Coasters for home. This is after lunch. So please if you can show me your awake and post your opinion in the chat box. The question is if the Shank of a ring was either foreign or US made and it was assembled to a US made ring head in the United States a foreign diamond was added and there was some further processing of the ring in the United States. 00:04:39.260 --> 00:04:50.620 Who thinks this ring would be considered made in USA and who would consider it foreign maid? OK, alright, we have some votes here we have some input. Foreign so far. 00:04:51.910 --> 00:04:54.380 Fine. Ohhh my gosh so far it's all fine. 00:04:55.550 --> 00:04:57.870 You one for USA. OK, foreign. 00:04:59.190 --> 00:04:59.890 Foreign. 00:05:01.340 --> 00:05:03.810 OK, thank you. I'm glad you guys are awake. 00:05:05.930 --> 00:05:06.560 So. 00:05:07.310 --> 00:05:14.440 Looks like we have mostly foreign out here form because of value. Interesting. OK and a couple USA. 00:05:18.770 --> 00:05:21.140 What kind of diamond? OK. 00:05:22.000 --> 00:05:25.990 Foreign essential character, OK. 00:05:28.710 --> 00:05:31.950 Foreign US, US. 00:05:33.780 --> 00:05:34.710 USA. 00:05:38.740 --> 00:05:43.840 OK. Thank you all for your input and we'll go ahead and uh move forward. 00:05:44.880 --> 00:05:49.640 I'm. I'm not gonna give you the answer yet. This is what we'll be discussing. 00:05:50.830 --> 00:05:59.240 Now let's take a closer look at what the importer stated was included in the processing of the ring in the USA. 00:06:00.050 --> 00:06:04.660 First of all, there was a thorough inspection of the ring, head, diamond and Shank. 00:06:05.580 --> 00:06:16.140 The ring had was assembled to the Shank. Next, the ring was sized. The diamond was set, and the ring head, and it was polished. And lastly it was plated. 00:06:21.030 --> 00:06:37.300 Now that I have told you a little bit more about the process saying let's have two new opinion polls, the first opinion poll is what you think the correct country of origin is for a ring that is made with a foreign made Shank. 00:06:39.390 --> 00:06:47.990 A US ring head, a foreign diamond and it is processed in the US. Is it a foreign ring or USA made ring? 00:06:50.520 --> 00:06:51.010 Foreign. 00:06:52.230 --> 00:06:52.960 USA. 00:06:54.240 --> 00:06:54.750 Born. 00:06:57.790 --> 00:07:00.400 OK. So we still have kind of a variety. 00:07:05.880 --> 00:07:07.710 And seeing a lot of foreigns. 00:07:20.180 --> 00:07:28.070 And somebody asked, oh, what are the US processes since that is important, I'm just gonna go back right now and say. 00:08:51.400 --> 00:09:20.860 Now further work or material added to a article in another country must affect a substantial transformation, and this is key substantial transformation in order to render such other country, the country of origin and a substantial transformation occurs when, as a result of a process an article emerges having a distinctive name character. 00:09:20.920 --> 00:09:36.810 Or use from the original material subjected to the process. If the manufacturing process is a minor one, which leaves the identity of the imported article intact, a substantial transformation has not occurred. 00:09:40.770 --> 00:09:48.460 Now let's take a look at a previous ruling, UM, that dealt with the country of origin of a gold ring that was cast in Hong Kong. 00:09:49.650 --> 00:09:55.230 And diamonds from India that was set in China. This is from 2019. 00:09:58.630 --> 00:10:02.040 Did a substantial transformation take place? 00:10:03.060 --> 00:10:04.000 What do you all think? 00:10:10.100 --> 00:10:12.260 No, no substantial transformation. 00:10:17.960 --> 00:10:20.140 So we're getting some nose and some yeses. 00:10:33.640 --> 00:10:35.280 OK, some yeses again. 00:10:36.280 --> 00:10:37.280 Some nose. 00:10:38.450 --> 00:10:43.800 OK, so moving on, what is the country of origin of the finished ring? 00:10:47.940 --> 00:10:51.980 What do you all think? Is a country of origin of the finished ring Hong Kong? 00:10:52.820 --> 00:10:55.160 I'm seeing a lot of Hong Kong, a India. 00:10:56.030 --> 00:11:05.130 That would be where the diamond was from Hong Kong, India. So some India, some Hong Kong. Anybody think China or Mexico? 00:11:08.280 --> 00:11:09.630 China, OK. 00:11:10.930 --> 00:11:11.460 India. 00:11:12.950 --> 00:11:13.700 Hong Kong. 00:11:15.040 --> 00:11:15.660 China. 00:11:18.570 --> 00:11:20.140 OK, Hong Kong. 00:11:21.910 --> 00:11:24.720 And what was the scenario again, I'll go back to it. 00:11:25.720 --> 00:11:29.190 So a gold ring cast in Hong Kong. 00:11:30.680 --> 00:11:31.540 Diamonds. 00:11:32.310 --> 00:11:35.260 From India and it was set in China. 00:11:36.860 --> 00:11:41.810 Did it substantial transformation take place and what is the country of origin? 00:11:43.750 --> 00:11:44.520 So China. 00:11:48.810 --> 00:11:49.510 Hong Kong. 00:11:51.320 --> 00:11:52.030 China. 00:11:53.390 --> 00:11:54.420 Nobody. Mexico. 00:11:57.400 --> 00:11:58.710 OK. We'll move forward. 00:12:00.990 --> 00:12:02.820 Yes, the the diamond. 00:12:05.550 --> 00:12:06.930 Uh was from India. 00:12:10.070 --> 00:12:11.770 It came cut and polished already. 00:12:13.270 --> 00:12:15.630 So I'm seeing some China, India. 00:12:16.580 --> 00:12:17.290 And. 00:12:18.010 --> 00:12:18.810 Hong Kong. 00:12:19.960 --> 00:12:30.830 OK. So moving forward, the country of origin for the finished ring was determined to be Hong Kong and that is where the gold ring was cast. 00:12:35.110 --> 00:13:05.300 OK, now let's take a look at another ruling dealing with the country of origin of jewelry. A ruling N 271750 from 2016. In this case, the gold ring was cast in the US, then diamonds from various countries were set in the Dominican Republic. Now, in this scenario, the setting of the diamonds was not was a lot more involved since it include a pavey setting with many small diamonds. 00:13:05.400 --> 00:13:10.870 In addition to the main diamond, and finally it was polished in the United States. 00:13:12.220 --> 00:13:22.870 So take a look at the scenario again. It's Goldring cast in the US. Diamonds from various countries. It was set in the Dominican Republic, including the Pavee setting. 00:13:24.110 --> 00:13:26.540 And it was published in the United States. 00:13:28.650 --> 00:13:36.240 So did a substantial take transformation take place? So everybody's saying so far US there seems to be a lot of. 00:13:36.920 --> 00:13:41.900 Uniformity there no no substantial transformation took place, and that it's the US. 00:13:42.910 --> 00:13:46.380 As see one that there was a substantial transformation. 00:13:54.150 --> 00:13:55.600 OK, so moving on. 00:13:56.970 --> 00:14:00.570 What is the country of origin of the finished ring? 00:14:01.740 --> 00:14:06.410 Is it United States, Dominican Republic various or India? 00:14:09.650 --> 00:14:13.910 So I'm seeing a lot for you as I'm seeing one for the Dominican Republic. 00:14:18.710 --> 00:14:23.140 Us so it looks like it's us or Dominican Republic. 00:14:25.330 --> 00:14:28.940 And some various I have one there for various. 00:14:32.390 --> 00:14:33.620 Dominican Republic. 00:14:37.130 --> 00:14:39.000 OK, so moving forward. 00:14:40.940 --> 00:14:51.260 The country of origin was determined to be the United States, where the gold ring was cast so you guys can start seeing a pattern on what? 00:14:51.990 --> 00:14:58.350 Has been determined to be important, uh when determining the country of origin of jewelry. 00:15:01.410 --> 00:15:27.820 So now in the headquarters ruling that I have been discussing, headquarters decided that they did not find that the inspecting the ring, head, diamond and Shank, the ring head integration, sizing of the ring polishing setting of the diamond in the ring head and plating to be considered sufficient processing to be considered substantial transformation. 00:15:33.210 --> 00:15:35.960 So to illustrate for further clarity. 00:15:36.950 --> 00:16:01.540 The country of origin of the diamond engagement ring engagement rings, UM say that three times fast is the country where the Shank is produced, and here it is illustrated with a foreign Shanks. So you have a foreign Shank, the USA ring head of Foreign Diamond USA processing, and the ring is considered form. 00:16:07.820 --> 00:16:20.770 And here it is illustrated with the USA may change. So you have a USA chank a USA made ring head a foreign Diamond USA processing boy. That's small font and. 00:16:21.820 --> 00:16:24.790 The ring was determined to be USA. 00:16:25.710 --> 00:16:30.140 So it really very much depends on where the Shank is made. 00:16:32.810 --> 00:16:38.080 Now, no, moving on to the next issue is, how should these rings be marked? 00:16:39.440 --> 00:16:44.850 Please add your comments to the chat box on how you think these rings should be marked. 00:16:52.480 --> 00:16:54.090 Die stamped. OK. 00:16:59.820 --> 00:17:01.040 Engraved on the ring. 00:17:05.570 --> 00:17:07.000 So we're getting some of the. 00:17:08.570 --> 00:17:10.180 Thy stamped inscribed. 00:17:11.910 --> 00:17:13.220 Edge to engraved. 00:17:14.910 --> 00:17:15.760 Hang tag. 00:17:17.010 --> 00:17:17.680 Label. 00:17:22.460 --> 00:17:27.400 Another hand tag in a way that is visible for the ultimate consumer. 00:17:29.830 --> 00:17:52.970 OK. So we'll go ahead. So now the importer stated that due to the size and delicacy of the diamond engagement rings, they are unable to edge the country of origin markings directly on the products. They also stated that die stamping or cast in the mold lettering on these products would not be legible for the customer. 00:17:54.140 --> 00:17:57.750 Umm, so they gave an example of how they propose to mark. 00:17:58.730 --> 00:18:22.520 The jewelry box on the outermost container with assembled in the US with diamonds made in India and setting made in Laos if it was made in Laos in case CBP did not find that the country of origin of the diamond engagement rings is the United States. 00:18:25.920 --> 00:18:30.460 So do you think that the proposed method of marking is acceptable? 00:18:34.010 --> 00:18:38.840 And just to to go back, they had wanted to mark the outermost container. 00:18:39.580 --> 00:18:52.020 Uh, with assembled in the United States, Diamond made in India setting made in Laos or whatever foreign country. So no, I see one. Yes, some yeses and some nodes. 00:18:55.580 --> 00:18:56.730 And now there should be a. 00:18:57.930 --> 00:18:59.750 A tag on the ring. 00:19:05.460 --> 00:19:09.310 No woman wants the country of origin inside her band. 00:19:10.290 --> 00:19:13.640 No woman wants the country of origin inside her band. I see. 00:19:15.300 --> 00:19:19.020 That's an interesting thought. That's OK. 00:19:24.400 --> 00:19:51.070 So 19 CFR 134, one D defines the term ultimate purchaser as generally the last person in the United States who will receive the article in the form in which it was imported. If an article is to be sold at retail and it's imported form, the purchaser at retail is the ultimate purchaser. And since the diamond engagement rings are not substantially. 00:19:51.160 --> 00:19:59.100 Transformed upon importation, the ultimate purchaser is the consumer who purchase it from the importer. 00:20:01.560 --> 00:20:20.380 So Umm, how should the finished rings be marked? Should it be die stamped? Does the marking on the box office? Is it exempt from marking? Should it be marked with a hang tag or adhesive sticker? So I'm seeing a lot of D's handbag AB the marking on the box offices? 00:20:21.070 --> 00:20:23.950 Another bee, a die stamped. 00:20:26.410 --> 00:20:31.660 My tea is another a die stamped another D with a hang tag. 00:20:32.860 --> 00:20:42.010 Another B that the marking on the box offices D hang tag or sticker C it is exempt from marking. 00:20:45.020 --> 00:20:45.690 D. 00:20:46.660 --> 00:20:48.660 Uh, with the hang tag or sticker? 00:20:51.320 --> 00:20:53.410 Be Rd OK. 00:20:55.290 --> 00:21:01.800 So B would be the marking on the box or hang tag. See exempt from marking. 00:21:02.710 --> 00:21:05.020 OK, so let's find out. 00:21:06.960 --> 00:21:12.330 So the answer is both C&D and let me explain. 00:21:14.470 --> 00:21:19.640 So for the engagement rings with a Shank from the United States. 00:21:20.360 --> 00:21:42.720 Since the country of origin for marking purposes will be United States, they will be exempted from marking from the country of origin marking requirements. Now, if the company wanted to mark the diamond engagement rings or the packaging containing these rings to indicate mid in USA, the marking must comply with the requirements of the Federal Trade Commission. 00:21:47.720 --> 00:21:48.200 And. 00:21:48.890 --> 00:22:19.780 The other correct answer was D and so these are for the engagement rings with a Shank that was from a foreign country. So not a USA made Shank. It was from a foreign country assembled in May not be used to indicate the country of origin of the diamond engagement rings since the assembly operations do not result in substantial transformation. Instead the diamond engagement rings. 00:22:19.900 --> 00:22:31.470 With a Shank from a foreign country should be marked with the name of the country from where the Shank is made, preceded by maiden or a product of. 00:22:34.230 --> 00:22:44.960 And here are the hang tags and I believe many of you mentioned this the OR adhesive stickers indicating the country of origin and this would be an acceptable method of marking. 00:22:45.690 --> 00:22:47.760 I am the diamond engagement rings. 00:22:52.260 --> 00:22:55.360 Now let's talk about the marking of the jewelry box. 00:22:56.620 --> 00:23:09.270 Should it be marked with the same country of origin as the ring, or should it be marked with the country of origin of the box? Or is it exempt from marking? Or does the marking on the ring suffice? What do you all think? 00:23:11.710 --> 00:23:13.020 The box so. 00:23:14.230 --> 00:23:15.620 The box has to be marked. 00:23:16.950 --> 00:23:21.140 So should it be marked with the same controversion as the ring as an A? 00:23:22.210 --> 00:23:27.830 Or with a country of origin of the box, as in B. So I'm seeing a lot of A's some's. 00:23:29.750 --> 00:23:32.300 Did the marking on the ring suffices. 00:23:34.120 --> 00:23:37.650 And some bees with a country of origin of the box. 00:23:38.670 --> 00:23:39.940 Seeing several bees. 00:23:41.510 --> 00:23:51.660 D marking on the back on the rings offices, more beers and 1A with the same color. Country of origin as the ring. 00:23:57.370 --> 00:24:02.690 D So we're kind of like, everywhere, see, or DRA. 00:24:08.230 --> 00:24:15.020 The correct answer is the jewelry box should be marked with a country of origin of the box. 00:24:18.080 --> 00:24:23.850 And I know that's not necessarily intuitive, but I'll explain why and it comes. 00:24:24.450 --> 00:24:37.730 Uh, it's the result of this case. Bausch and Lomb incorporated versus the United States. UM at the Court of International Trade, considered the question of whether imported glasses that were. 00:24:38.470 --> 00:24:45.290 Imported glasses that were imported. Sorry, imported glass sunglass cases. 00:24:46.190 --> 00:24:51.270 Uh, we're disposable containers for purposes of country of origin marking requirements. 00:24:52.490 --> 00:25:23.240 However, the court determined that because of the durability and protective quality of those particular sunglass cases and that they were not similar to cans, bottles, paper or polyethylene bags or paper board boxes, which 19 CFR One 3424 lists as examples of disposable containers not required to be marked individually. 00:25:23.940 --> 00:25:34.010 With their own country of origin. So given that the jewelry cases did not appear to be of a kind, that is typically disposed of. 00:25:35.260 --> 00:25:39.320 They are required to be marked with their own country of origin. 00:25:40.400 --> 00:25:41.030 Draft. 00:25:42.550 --> 00:25:43.820 Yeah, sorry. 00:25:46.710 --> 00:26:15.660 So now that we've been talking about all these engagement rings, let's take a little trivia break and see if any of you know a little bit of history regarding engagement rings. And do you know when was the first time that a diamond appeared on an engagement ring? Was it when Roman general Marc Anthony and this is not Jlo's ex Marc Anthony? 00:26:15.780 --> 00:26:38.010 The post it Cleopatra Queen of Egypt or Louis the 15th of France, proposed to Madame Pompadour or Archduke Maximilian of Austria proposed to Mary of Burgundy, or lastly, when Prince Albert proposed to Queen Victoria. So I'm seeing a lot of Prince, Prince Albert or. 00:26:38.700 --> 00:26:40.440 Marc Anthony or. 00:26:41.180 --> 00:26:44.670 Here, who said? See D The last one. 00:26:45.390 --> 00:26:46.140 See. 00:26:47.010 --> 00:26:52.640 OK, so DDI am Maximilian OK. 00:26:53.720 --> 00:26:56.750 And that that's in bold. 00:26:57.490 --> 00:26:59.430 So a lot of seeds now. 00:27:04.710 --> 00:27:10.220 And roomy knows this. Maximilian. Alright. OK, let's hear from is right. 00:27:12.180 --> 00:27:13.400 Let's take a quick look. 00:27:15.600 --> 00:27:16.710 She is right. 00:27:17.340 --> 00:27:43.510 The correct answer is worth when Archduke Maximilian of Austria, Austria, proposed to marry Burgundy and this was in 1947 night 1477, Archduke Maximilian of Austria commissioned the very first diamond engagement ring on record for Mary of Burgundy, and this sparked a trend for diamond rings among European aristocracy and nobility. 00:27:44.680 --> 00:27:48.700 Umm. And do any of you all know how? 00:27:49.570 --> 00:27:53.430 If if it was forever as the diamond supposed to be. 00:27:54.630 --> 00:27:55.000 Did. 00:27:55.880 --> 00:27:59.090 How long they're marriage lasted, or if it lasted. 00:27:59.830 --> 00:28:01.380 Till the end. Does anyone know? 00:28:02.840 --> 00:28:05.120 Just out of curiosity now. 00:28:09.090 --> 00:28:09.930 Off with their head. 00:28:10.010 --> 00:28:10.300 No. 00:28:11.490 --> 00:28:14.620 Yeah, that could be. That would be more like England, right? 00:28:15.990 --> 00:28:30.810 And no idea. OK, well, this one. Apparently they did marry for love. And they had three children. But unfortunately, after five years, she had a horseback riding accident. So. 00:28:32.180 --> 00:28:37.880 That till death do us part. So yes, correct. OK, moving on. 00:28:39.060 --> 00:28:55.660 The second, uh ruling that I will be reviewing today is headquarters ruling H20, eight 1923 from November 2018 and the subject of the ruling is the classification of an electronic flashing button. 00:29:00.040 --> 00:29:07.160 Now a little bit of information about this particular item. It is a circular hard plastic. 00:29:08.400 --> 00:29:37.890 With a PIN or clip mounted on the back and within the plastic housing there is an expression or saying such as happy Birthday. The greatest I made it et cetera. The button incorporates four rapidly flashing LED lights. The item is battery powered and has an on off switch located on the back and the button can be worn on a lapel. 00:29:37.960 --> 00:29:44.170 Or a shirt. It is a novelty item which is to be worn on festive occasions. 00:29:47.490 --> 00:30:08.760 The ruling, considered which one of the following headings uh the electronic flashing button should be classified in heading 7117, which provides for imitation jewelry heading 9505, which provides for festive articles, or heading 8543, which provides for electrical machines and apparatus. 00:30:11.440 --> 00:30:27.070 So it's your turn to weigh in before we review this ruling under which of these Hennings do you think that the electronic flashing button should be classified as heading 7117 for imitation jewelry? 00:30:27.630 --> 00:30:34.560 Umm, I'm seeing a lot of bees, so that would be heading 9505 as festive articles. 00:30:35.780 --> 00:30:45.930 Or anybody for heading any 543 as electrical machines or apparatus. I mean it did have somebody 9929. 00:30:46.770 --> 00:30:47.300 Umm. 00:30:49.560 --> 00:30:53.350 It did have a battery and on off. 00:30:54.650 --> 00:31:02.800 Or, as specifically provided for under heading Diety 929 as flashing electronic buttons, I got one vote for that. 00:31:04.890 --> 00:31:07.180 So I'm seeing some A's and B's. 00:31:08.400 --> 00:31:09.950 One see here. 00:31:12.810 --> 00:31:13.580 A sea. 00:31:18.560 --> 00:31:19.570 Any more votes? 00:31:21.680 --> 00:31:28.990 So D is the last one as an electronic flashing button specifically provided for. 00:31:30.860 --> 00:31:44.370 It is tricky, right knowing, UM, highly classified these items that can overlap among various headings, so I'm not gonna give you the final answer yet since I will be discussing it. 00:31:44.450 --> 00:32:04.530 Umm in more depth as we go through each heading potential heading. However I can tell you that heading 9929 does not exist and if it did there probably would be no need for this ruling as it would be specifically provided for. So that was kind of a trick question, I apologize. 00:32:05.850 --> 00:32:16.400 So moving on, let's begin with heading 8543, which covers electrical machines and apparatus, and I know a couple of you voted for that. 00:32:17.450 --> 00:32:27.180 Now the explanatory notes for heading 8543 state that if the merchandise is covered more specifically by a heading. 00:32:28.260 --> 00:32:43.320 Of another chapter of the tariff. Then it would not be classified in 8543. So could it be classified more specifically by any one of the other headings we are considering? 00:32:47.310 --> 00:32:54.900 So do you think that this could be considered jewelry? You know, some more specifically. So I'm seeing a, yes. 00:32:56.110 --> 00:33:01.600 So more specifically provided for us. So yeah, I'm seeing a couple yeses here. Yes. 00:33:04.680 --> 00:33:06.350 Anymore? Yeses or Nos. 00:33:08.030 --> 00:33:12.160 So yeah. See ohh OK, one now and one more. 00:33:14.790 --> 00:33:19.040 OK. Yes, yes. OK. No, another no. 00:33:22.530 --> 00:33:26.490 Personally, no. But with customs it could be yes. OK. 00:33:27.650 --> 00:33:54.300 Yeah, well, it's let's figure out here what it says. So in review of the electronic flashing button, headquarters noted that it features a PIN or clip upon which the button is mounted. And it is the type of pin or clip that it is that is routinely affixed to jewelry, pins or brooches that are worn on a lapel or a shirt. 00:33:56.950 --> 00:34:04.830 Therefore, the electronic flashing buttons are prima facie classifiable and heading 7117. 00:34:05.710 --> 00:34:07.010 As imitation jewelry. 00:34:09.910 --> 00:34:23.230 So the merchandise is potentially covered more specifically by another heading. Therefore it would not be classified in the heading 8543. Yeah, she does not look happy. That's grumpy cat. 00:34:27.120 --> 00:34:51.080 Out a quick trivia break on the topic of pins or brooches. Do any of you know who wrote the book? Read my pins about their use of jewelry to convey foreign policy messages. Was it Queen Elizabeth, Hillary Clinton, Margaret Thatcher, or Madeleine Albright? So I'm seeing. 00:34:51.860 --> 00:34:54.270 DJ's CD's. 00:34:54.890 --> 00:34:55.620 Dees. 00:34:56.550 --> 00:34:59.700 Uh people really seem to know this day is a lot of D's here. 00:35:00.730 --> 00:35:04.980 You're gonna. Yeah. OK, another D Albright. 00:35:06.410 --> 00:35:08.880 So a lot of these, Madeline. 00:35:10.560 --> 00:35:12.570 So a lot of you seem to. 00:35:14.450 --> 00:35:16.250 Be familiar with this. 00:35:16.960 --> 00:35:18.190 So a lot of deeds. 00:35:20.260 --> 00:35:26.080 OK, so I'll give you a couple more seconds. What me, I know I don't. 00:35:28.140 --> 00:35:33.140 I don't wear jewelry to convey foreign policy messages. 00:35:38.910 --> 00:35:44.360 OK, let's find out who it was. It was Madeleine Albright. And I think a lot of you. 00:35:48.750 --> 00:36:10.340 And a snake pen Albright wore was a response to Iraqi officials description of her as an unparalleled serpent. She also once wore a bug pin to let Russian diplomats know that the US was unhappy that a State department room had been bugged. 00:36:11.040 --> 00:36:12.410 That's pretty big bug. 00:36:13.580 --> 00:36:19.150 You can see it on her lapel there speaking, I guess, in front of the United Nations. 00:36:23.410 --> 00:36:34.470 OK. So moving on, while the electronic flashing pins are potentially classifiable in heading 7117, heading 9505 must also be considered. 00:36:35.220 --> 00:36:41.160 And classification of merchandise as festive articles under Chapter 95 requires that you. 00:36:41.810 --> 00:37:12.730 That the article satisfy two criteria. One, it must be closely associated with a festive occasion, and two, it must be used or prints or displayed principally during that festive occasion. In addition, the item must be closely associated with a festive occasion to the degree that the physical appearance of an article is so intrinsically linked to that festive occasion that it's used during. 00:37:13.360 --> 00:37:18.360 Any other time periods would be very abnormal, aberrant, aberrant. 00:37:21.830 --> 00:37:26.920 So if the buttons are potentially classifiable under heading. 00:37:28.410 --> 00:37:35.030 7117 and heading 9505 how do we determine which one applies? 00:37:36.110 --> 00:37:41.860 GRI 3, A, which states in pertinent part when the goods are. 00:37:42.620 --> 00:37:51.900 Prima facie, classifiable under two or more headings, the heading which provides the most specific description shall be preferred to. 00:37:52.750 --> 00:37:55.530 Umm. Headings, providing a more general description. 00:37:59.230 --> 00:37:59.800 So. 00:38:00.460 --> 00:38:04.170 Which one do you think is most specific? 00:38:06.080 --> 00:38:10.040 So Lasten heading would be if it was Jari 3C. 00:38:10.690 --> 00:38:20.110 We're looking at GR3A here, so do you all think the imitation jewelry or festive articles or you are a cat or dog person? 00:38:25.160 --> 00:38:31.520 So I'm seeing some festive so you think festive is more, more general. You're a cat person, OK? 00:38:32.800 --> 00:38:33.040 Like. 00:38:35.180 --> 00:38:39.210 Imitation jewelry. OK, festives. I'm seeing kind of. 00:38:40.170 --> 00:38:40.720 Umm. 00:38:42.750 --> 00:38:45.480 Almost like 5050 that you're a dog person. 00:38:46.600 --> 00:38:50.110 I have one of each, so used to have four but. 00:38:53.200 --> 00:39:03.840 Any 505. OK, so I'm seeing kind of like a 5050 on where you think it might end up? 00:39:04.820 --> 00:39:06.660 Or what is more specific? 00:39:07.460 --> 00:39:08.610 So let's find out. 00:39:10.600 --> 00:39:33.010 Now, imitation jewelry is limited to small items of personal adornment that do not contain an appreciable amount of precious or semi precious stones or metal, making them imitation and festive. Articles, on the other hand, need to be closely associated with and used or displayed during a festive occasion. 00:39:34.470 --> 00:39:41.750 Now, because heading 9505 covers a far broader range of items than heading 7117. 00:39:42.660 --> 00:40:06.500 In this case, heading 7117 is more specific. Heading 7117 is also more specific because it describes the item by name imitation jewelry that rather than a class festive articles, a category festive articles, the imitation jewelry heading is more specific than the festive articles. 00:40:07.730 --> 00:40:13.140 Umm, heading because it covers a narrower set of items and as a result. 00:40:13.860 --> 00:40:18.640 Are the imported merchandise is classifiable under heading 7117? 00:40:19.750 --> 00:40:23.520 Rather than under heading 9505. 00:40:30.070 --> 00:40:46.580 By application of GRID one and three AV electronic flashing buttons are classified and heading 7117 specifically in heading 7117 ninety Seventy 57500 which provides for a plastic jewelry. 00:40:50.260 --> 00:41:10.430 So that concludes my discussion of these two headquarters rulings. And here is the website where this ruling where this webinar will be posted as well as other helpful CBP webinars. And here is the website where you can request a binding ruling. 00:41:13.660 --> 00:41:16.980 And here is my contact information if you would like to reach me. 00:41:17.730 --> 00:41:25.180 I thank everyone for attending and does anyone have any questions I see here isn't the pin made of metal? 00:41:26.050 --> 00:41:38.500 Umm, it probably had some metal, but it was predominantly plastic and probably the visual appeal large part of it was from the plastic. Thank you. Thank you so much. 00:41:39.170 --> 00:41:40.350 Thank you. I appreciate it. 00:41:48.260 --> 00:41:48.800 Thank you. 00:41:53.320 --> 00:42:01.700 Any updates on the headquarter ruling on the cubic zirconia jewelry? Not yet. Sorry. I know people are interested in that. Not yet. 00:42:02.920 --> 00:42:03.400 Thank you. 00:42:07.990 --> 00:42:14.800 And I'll I'll go back to the uh the link where the oh, there it is. Where the Jenny. 00:42:16.030 --> 00:42:18.190 Posted and and I want to thank very much. 00:42:18.670 --> 00:42:38.410 I'm Jenny and Rumi and Miriam and Fang for making this webinar possible and making it easy for me with all of their incredible expertise. I really appreciate it. Thank you. Thank you so much. 00:42:47.420 --> 00:42:47.960 Thank you. 00:42:48.810 --> 00:42:50.100 And yet the questions. 00:42:51.850 --> 00:42:52.420 Thank you. 00:42:59.170 --> 00:43:01.250 Thank you so much. Really appreciate it. 00:43:02.790 --> 00:43:04.020 Hopefully it was clear. 00:43:17.120 --> 00:43:19.650 So I think thank you so much. Thank you everyone. 00:43:21.260 --> 00:43:35.060 Let me see our will there be ohh uh for ICP. I definitely would uh like to work towards having a jewelry ICP in the near future. Thank you Ricardo. Appreciate it. 00:43:37.700 --> 00:43:38.520 Thank you, Ivan. 00:43:46.100 --> 00:43:46.620 Thanks. 00:43:51.100 --> 00:43:52.450 Any other questions? 00:43:58.710 --> 00:43:59.250 Thank you. 00:44:07.070 --> 00:44:15.710 I'm glad you enjoyed being part of the action and I appreciate your participation. It really makes a big difference for me. Thank you. 00:44:25.790 --> 00:44:35.580 Looks like we don't have any more questions. I thank you all very much for attending and I thank you all for bearing with me and participating. I really appreciate it. 00:44:36.800 --> 00:44:37.450 Thank you. 00:44:40.610 --> 00:44:52.190 Apart from this webinar, don't have any currently uh scheduled, but there is definitely many webinars that are being offered by national import specialist. 00:44:52.280 --> 00:44:52.770 Umm. 00:44:53.700 --> 00:44:55.130 I'm almost weekly. 00:44:57.610 --> 00:45:01.480 And there should be the schedule on the CBP website. 00:45:04.730 --> 00:45:05.370 Thank you all. 00:45:27.970 --> 00:45:32.790 Ah, there you go. There's the list. June of UH webinars. Thank you. 00:45:37.320 --> 00:45:45.950 Yeah, there's many webinars. Uh provided by all the different national import specialist here at customs. 00:45:47.610 --> 00:45:52.340 Covering a wide variety of merchandise and issues. 00:45:53.410 --> 00:45:56.900 If any of you all I'll are interested, great. 00:46:44.300 --> 00:46:48.050 So I don't see any more questions and thank you all for attending.