For goods entering the United States, CBP starts from your invoice, not from a fixed book of values: the legal basis of appraisement is transaction value — “the price actually paid or payable for the merchandise when sold for exportation to the United States” under 19 U.S.C. 1401a(b) — with specified additions such as buyer-supplied molds, packing, and selling commissions. There is no customs database of jewelry values that replaces your declared price; a published value enters the picture only when CBP doubts your figure, and then the statute prescribes a hierarchy of statutory values rather than a table lookup. Classification is the other half: finished S925 jewelry lands in HTS 7113.11, where the duty rate is 5%, 6.3%, or 13.5% depending on the ten-digit line, and synthetic moissanite set into the piece carries no separate rate at all.
Does US Customs Use My Invoice Price or Its Own Database Value?
Neither the tariff statute nor the customs regulations give CBP a database of standard values for sterling silver jewelry. Appraisement begins with your own transaction value: the total payment, direct or indirect, made or to be made by the buyer to or for the benefit of the seller. The relevant exclusions are narrow — international transportation, insurance, and related services come out of the dutiable price if separately identified, and so do any duties or taxes, hence the gap between an FOB Shenzhen quote and a CIF quote for the same order.
A government value only replaces yours when transaction value cannot be used — when the price reflects conditions CBP cannot value, or is formally rejected. At that point 19 U.S.C. 1401a prescribes a fixed sequence, not a lookup table: transaction value of identical merchandise, then similar merchandise, then deductive value (resale price minus margins), then computed value (materials, fabrication, profit), then a fallback. This is the practical difference from the countries buyers sometimes describe, where a customs computer assigns a reference price per gram of silver jewelry. In the US system, your invoice is the anchor; everything else is what happens when that anchor is attacked.
Two consequences follow for an S925 buyer. First, an invoice deliberately written low is not a database you are competing against — it is a statement CBP can test against your purchase records, payment trails, and past entries. Second, an invoice omitting dutiable additions (covered below) is understated even if every figure on its face is accurate.
What Counts as the Transaction Value on an S925 Moissanite Order?
For a typical wholesale or OEM order the transaction value is the full price for export sale — deposit and balance together. If your terms are the industry-standard 30% T/T deposit with 70% before shipment, both legs are part of one price actually paid or payable; entering the goods at the deposit figure alone is a material understatement, not a technicality. A negotiated discount is fine — the regulation looks at the price “without regard to its method of derivation” — and a post-importation rebate or price decrease is disregarded afterward.
On top of the sale price, 19 CFR 152.103(b) adds four items when the buyer incurs them and they are not already in the price: packing costs, selling commissions, royalties or license fees paid as a condition of sale, and the apportioned value of any assist. For jewelry buyers the assist is the one that surprises people:
- A mold or master model you supply free to the factory is dutiable. Where the buyer acquires tools, dies, or molds from an unrelated seller and provides them free or below cost, the regulation values the assist at the cost of acquisition and apportions it across production, following generally accepted accounting principles — commonly over anticipated output. Illustration: a $2,000 mold spread over 4,000 expected pieces is a $0.50-per-piece addition. Where the design work was produced in the United States, the regulation treats US-produced designs supplied to a foreign producer as not dutiable.
- A mold the factory owns is not an addition. Under our published OEM/ODM terms, full custom orders carry a 50–100-piece MOQ and a one-time setup/mold fee — charged when the style is created and never again — while the molds and CAD files stay yours exclusively, are stored free for three years, and are never reused for another customer; unchanged reorders carry no tooling fee at all. Because the setup fee pays the factory to cut the mold, that tooling cost is part of the price actually paid or payable, so there is nothing to add at entry. The distinction to keep straight is who acquired the mold and who bears its cost, which is how we explain setup-fee fairness in our guide to private-label setup fees and reorder policy.
- Buyer-supplied files versus buyer-supplied property. Sending CAD files for your private-label design is part of ordering مجوهرات مواسانيت حسب الطلب; shipping the factory a purchased master model or setting tools is an assist. The second one has a duty value; the first generally does not.
If any addition applies but the information to value it does not exist, the regulation says transaction value cannot be determined — which throws the entry onto the slower statutory hierarchy. That is the administrative reason to decide mold ownership and commission arrangements before the first shipment, not after CBP asks.
Which HTS Line and Rate Apply to S925 Jewelry with Moissanite?
Classification comes first, because the rate hangs off the line, and a set moissanite does not change the heading. Under the General Rules of Interpretation, finished jewelry of precious metal classifies in heading 7113; the subheading for silver reads “Of silver, whether or not plated or clad with other precious metal,” so rhodium-plated sterling and 18K gold vermeil over 925 sit in the same place as bare silver. The three ten-digit lines under 7113.11 in the Harmonized Tariff Schedule (searchable at hts.usitc.gov) carry different General rates:
- 7113.11.10.00 — 6.3%: rope, curb, cable, chain and similar articles produced in continuous lengths, whether or not cut to specific lengths and whether or not set with imitation pearls or imitation gemstones, suitable for use in the manufacture of articles of this heading. This line is written for chain stock; whether a finished, clasped tennis chain belongs here or in the “other” line is a question for your broker before the first entry.
- 7113.11.20.00 — 13.5%: articles valued not over $18 per dozen pieces or parts. This is the line that surprises new importers: within silver jewelry, the cheap tier pays the higher ad valorem rate.
- 7113.11.50.00 — 5%: other — the line most finished S925 moissanite pieces land on, with reporting in grams, so net weight on the invoice matters.
For comparison, the gold side of the same heading (7113.19) runs roughly 5% to 7% across its comparable lines, and base-metal imitation jewelry in 7117.19 enters at 8% on its “other” line — so a base-metal core misdeclared as sterling is both a quality fraud and a classification error. The moissanite itself has no rate to stack: stones “cut but not set, and suitable for use in the manufacture of jewelry” fall under heading 7104 for synthetic or reconstructed stones and enter free under 7104.99.10.00 — but that line applies to loose stones. Once the stone is set into an S925 pendant, bracelet, or ring before import, the assembled piece enters as jewelry in 7113, and the stone rides inside it. Buyers who import loose moissanite separately for local setting face the opposite sequence — the packing list and the stage of manufacture must describe the same reality.
When Can CBP Reject My Invoice Price, and What Does That Cost?
Transaction value is unusable when the sale carries restrictions or conditions CBP cannot value, and for related-party sales unless the price passes one of two tests: the relationship did not influence the price, or the value closely approximates test values for identical or similar merchandise. There is no fixed percentage safe harbor — the regulation says so explicitly, which is why “we allow 5% between related prices” is folklore. When CBP states grounds for rejection, the importer has 20 days to respond in writing; what wins that response is documentation, and the natural set is the purchase contract, the payment record matching the invoice, and a cost build-up of the piece itself.
The penalty framework for an invoice written below what you actually paid is 19 U.S.C. 1592: entering merchandise by a material false statement or material omission, even without revenue loss. Negligence exposes you to the lesser of the domestic value of the shipment or twice the duties lost (or 20% of dutiable value where no duty was lost); gross negligence raises those to four times the lost duties or 40%; fraud runs up to the full domestic value. A prior disclosure before CBP opens a formal investigation cuts a negligence case to interest on the duties tendered — which is why fixing a discovered valuation error yourself is cheaper than having it found.
Note the interaction with the value bracket described above: on silver jewelry the under-$18-per-dozen tier pays 13.5% while higher-value pieces pay 5%. The folk wisdom that a lower declared value always means less duty does not survive contact with this heading — and moving an entry across that bracket by understatement creates a second, independent classification violation on top of the valuation one.
What Does a Defensible S925 Invoice Look Like When CBP Questions the Value?
The commercial invoice does not need separate lines for metal, stones, and labor — the assembled piece is classified as one article, and duties are computed on the whole transaction value. What a defensible file contains is a cost build-up kept as backup documentation, not printed as duty lines: metal weight and the silver price applied, moissanite cost per stone by size, setting and plating labor, then the quote arithmetic. When an officer questions the declared value, your broker answers with that build-up plus payment proof — not with a promise to ask the factory. Buyers running مجوهرات مواسانيت بالجملة orders against a stock price list already have most of this on file; the discipline is archiving it against the PO so it survives staff turnover.
The invoice face itself should carry, per line: a specific description (sterling silver S925 with synthetic moissanite, style code, finish), the ten-digit HTS number, quantity and unit of measure, net weight in grams, unit price and currency, the Incoterm that shows which charges are inside the price (FOB Shenzhen keeps international freight out of dutiable value), and the full order value — deposit plus balance. If you pay a buying agent a selling commission, or purchase packing separately, add those as identified amounts. If a mold you own travels with the production, declare the apportioned assist. None of this is padding; each field is one of the facts an entry is legally required to support, and our earlier walkthrough of US customs documents for S925 entries covers the companion paperwork — composition declarations, XRF reports, and the 925 mark.
FAQ: Valuation Questions S925 Buyers Ask Most
Is there a minimum declared value below which jewelry is not taxed?
No. Since the suspension of de minimis duty-free treatment effective August 29, 2025, low-value batches enter formally and are assessed like any other entry — our guide to what CBP actually requires for an S925 entry walks through the documents that change at that threshold.
Does the GRA certificate on the moissanite change the duty rate?
No. Certification documents — GRA reports on our D-color, VVS1, 3EX-cut, laser-inscribed stones, or any third-party assay — support quality claims and marketplace listings. Classification and valuation run on the goods and the price, not on the certificate.
One PO ships in three monthly releases — which price applies to each entry?
Each release is entered on its own invoice and its own transaction value at the time of that shipment. When each entry’s paperwork comes up, our guide to US customs documents for S925 entries covers what each release needs — composition declarations, per-casting-batch XRF reports, and the invoice facts a proper appraisement requires.
What happens if CBP decides the value is higher than my invoice?
CBP states its grounds and the importer answers in writing within 20 days — typically with the contract, payment records, and the cost build-up described above. Unresolved, the entry liquidates at the government’s determination, with protest rights afterward; penalties under 1592 remain possible if the original declaration was false or omitted the additions, so the strongest move is a file that matches the money that actually moved.
