OT:RR:CTF:VS H359026 ACH
Marianne Rowden
Brownstein Hyatt Farber Schreck, LLP
600 Massachusetts Ave. NW, Ste. 400
Washington, DC 20001
RE: Subheading 9817.60.00, HTSUS; Broadcasting Equipment, Timing Equipment, and
Boats related to the 2028 Olympic and Paralympic Games
Dear Ms. Rowden:
This is in response to your ruling request, dated March 18, 2026, on behalf of your client,
the Los Angeles Organizing Committee for the 2028 Olympic and Paralympic Games (“LA 28”),
concerning the eligibility for duty-free treatment under subheading 9817.60.00, Harmonized
Tariff Schedule of the United States (“HTSUS”), of certain equipment and goods related to the
preparation, operation, and competition of the 2028 Olympic and Paralympic Games to be held
in the United States. A meeting was held with the representatives of LA 28 on April 29, 2026.
FACTS:
The Olympic and Paralympic Games involve more than 15,600 athletes from 200
countries, 75,000 volunteers, 150,000 contractors, and 5,000 Technical Officials who will
participate in 560 medal events during the Games. The Olympic Games will run from July 16,
2028 to July 30, 2028, and the Paralympic Games will run from August 15, 2028 to August 27,
2028.
The Olympic and Paralympic Games will take place in a number of venues in and around
the greater Los Angeles-Long Beach, CA area. As a result, LA 28 expects the articles described
in this ruling request to enter through multiple ports, including but not limited to Los Angeles
International Airport and Los Angeles/Long Beach Seaport.
LA 28 expects to import articles used by athletes, officials, and volunteers participating in
the games; information technology (“IT”) and equipment used to broadcast the games; and
construction equipment, fittings, and kits used to build temporary structures to host and
broadcast the Games. LA 28 also intends to include donation and legacy provisions which may
include certain venue infrastructure or distribution to non-profit organizations and community
programs.
At this time, LA 28 intends to import the following goods:
• Olympic Broadcasting Services (“OBS”) Equipment—OBS is the International Olympic
Committee (“IOC”)-designated host broadcaster for the Games and is responsible for
producing the international broadcast signals. Consistent with that role, OBS and/or its
contractors will temporarily import into the United States specialized broadcast studio
and production equipment (including prefabricated walling panels, metal structures,
flooring, fixtures, cabling and tools for studio fit-out, cameras, lenses, audio equipment,
transmission and networking equipment, control-room and production systems, and
related parts, accessories, test gear, and packing/transport materials) for exclusive use in
producing and transmitting coverage of the Games. The OBS equipment is shipped
directly from one Olympic venue to be stored, tested, and set up at the next selected
venue (i.e., from the 2026 Milan/Cortina Games to the 2028 Los Angeles Games). LA 28
states that these articles are not intended for sale or distribution to the public.
• OMEGA Timing and Results Equipment—OMEGA, as the IOC-appointed Official
Timekeeper, and/or its authorized service providers will import timing, measuring,
scoring, and results systems required for the Olympic and Paralympic Games, including,
as applicable, photo-finish and start systems, transponders, touchpads, sensors, cabling,
displays, timing consoles, data processing equipment used for results, spares, tools,
calibration equipment, and related support items. LA 28 states that these articles will be
used exclusively in connection with the Games and are not intended for sale or
distribution to the public.
• Boats—LA 28 and/or accredited stakeholders (including International Federations and
competition operators, as applicable) will import certain boats and sailing boards for kite
and windsurfing disciples for exclusive use in connection with Olympic and Paralympic
competition and Games operations (e.g., training and competition boats and sailing
boards for kite and windsurfing disciplines, field-of-play operations, safety and rescue
support, on-water officiating support, technical operations support, and similar Games-
only purposes). The boats and sailing boards are imported two years in advance of the
Games to become acclimated to the weather in the Los Angeles and Oklahoma City areas
and are used for training purposes in a new environment. LA 28 states that such boats
and sailing boards are not intended for sale or distribution to the public and will be
exported, disposed of other than by sale, or otherwise handled consistently with the
requirements of Subchapter XVII, Chapter 98.
LA 28 states that these goods will be used for the 2028 Olympic and Paralympic Games
by participants, officials or accredited members of delegations thereto, including, but not limited
to the IOC, IOC-controlled entities, National Olympic Committees, National Paralympic
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Committees, the International Paralympic Committee (“IPC”), International Federations, Rights-
Holding Broadcasters, the Official Timekeeper, IOC Marketing Partners, and media.
ISSUE:
Whether the OBS equipment, OMEGA timing and results equipment, and boats and
sailing boards related to the preparation, operation, and competition of the 2028 Olympic and
Paralympic Games are eligible for duty-free treatment under subheading 9817.60.00, HTSUS.
LAW AND ANALYSIS:
Subheading 9817.60.00, HTSUS, provides duty-free treatment for:
Any of the following articles not intended for sale or distribution to the public:
personal effects of aliens who are participants in, officials of, or accredited
members of delegations to, an international athletic event held in the United
States, such as the Olympics and Paralympics, the Goodwill Games, the Special
Olympics World Games, the World Cup Soccer Games, or any similar
international athletic event as the Secretary of the Treasury may determine, and of
persons who are immediate family members of or servants to any of the foregoing
persons; equipment and materials imported in connection with any such foregoing
event by or on behalf of the foregoing persons or the organizing committee of
such an event, articles to be used in exhibitions depicting the culture of a country
participating in such an event; and, if consistent with the foregoing, such other
articles as the Secretary of the Treasury may allow.
Subheading 9817.60.00, HTSUS, was added to the HTSUS with the enactment of the
Miscellaneous Trade and Technical Corrections Act of 2000, Public Law 106-476 (November 9,
2000). The Senate Report stated with regard to this new provision:
This provision would amend subchapter XVII of chapter 98 of the HTS by
inserting a new heading 9817.60.00 for duty free treatment of the personal effects
of participants in, officials of, and accredited members of delegations to,
international athletic events, including the paralympics, held in the United States
provided that these items are not intended for sale or distribution in the United
States. H.R. 2715 would also exempt the articles covered under this provision
from taxes and fees and would give the Secretary of the Treasury discretion to
determine which athletic events, articles, and persons are covered under this
provision.
See S. Rep. No. 503, 106th Cong., 2nd Sess. (2000) (“Tariff Suspension and Trade Act of 2000”).
The House Report contains virtually identical language with regard to the provision. See H.R.
Rep. No. 789, 106th Cong, 2nd Sess. (2000) (“Miscellaneous Trade and Technical Corrections Act
of 2000”).
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In explaining the reason for the creation of subheading 9817.60.00, HTSUS, both the
House and Senate Reports stated:
The Committee recognizes the importance of international athletic events and the
tremendous efforts of the athletes and participants. Although athletes and other
officials connected with certain sporting events are currently afforded duty free
treatment for their personal belongings and equipment under current law, such
treatment will expire in December 2002. This legislation will give athletes and
participants of future competitions certainty regarding their future duty liability.
See S. Rep. No. 503, 106th Cong., 2nd Sess. (2000), and S. Rep. No. 503, 106th Cong., 2nd Sess.
(2000).
The Olympics and Paralympics are specifically enumerated under subheading
9817.60.00, HTSUS, as eligible international athletic events and therefore, this requirement
under subheading 9817.60.00, HTSUS, is met. Moreover, you state that the items are not offered
for sale or distribution to the public. We are therefore satisfied that the merchandise constitutes
“articles not intended for sale or distribution to the public” for purposes of subheading
9817.60.00, HTSUS.
Accordingly, the last issue is whether the merchandise constitutes “equipment and
materials imported in connection with any such foregoing event by or on behalf of the foregoing
persons or the organizing committee of such an event . . .”. Based on the information you
provided, some of the requested items fall within the purview of subheading 9817.60.00,
HTSUS, as they have already been approved as being “in connection with” an international
athletic event in previous rulings issued by CBP. For example, in Headquarters Ruling Letter
(“HQ”) H345037, dated April 9, 2025, CBP determined that the following personal effects and
necessary and support equipment related to the FIFA Club World Cup 2025™ and the FIFA
World Cup 26™, fell within the purview of subheading 9817.60.00, HTSUS:
• Personal items for FIFA Client Groups;
• Food and beverages for personal use by FIFA Client Groups;
• Alcoholic beverages for personal use by FIFA Client Groups;
• Tobacco products for personal use by FIFA Client Groups;
• Sports equipment for tournament use;
• Referee equipment for tournament use;
• Team training equipment for use by teams for training for tournament;
• Infrastructure equipment/temporary infrastructure equipment & equivalent for
tournament and event use;
• Special events goods/stage equipment/venue equipment & equivalent for tournament and
event use;
• Pitch/field management equipment to support and maintain practice and match fields;
• Uniforms for team and all FIFA tournament and event use;
• Furniture & office equipment & equivalent for staging tournament and events;
• Catering equipment for staging tournament and events;
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• Anti-doping samples collection & equipment to ensure compliance with international
regulations for the tournament;
• Medical equipment to be used by FIFA Client Groups for tournament use;
• Broadcast, audio, & media equipment to be used by accredited media and the like to be
used for tournament and events;
• Technology equipment to be used by FIFA Client Groups for staging and production of
tournament and events;
• Vehicle & transport equipment for use in tournament and events;
• Promotional materials for promotion and use in tournament and events;
• Commercial affiliate and partner/sponsor goods for staging and production for
tournament and events;
• Hospitality items for displaying the culture of their country, team, sport, or bid for future
events for use in tournament and events; and,
• Participant member of association goods, i.e., personal items of teams for tournament and
event use for execution of the games.
In Mont v. United States, 587 U.S. 514 (2019), the Supreme Court wrote: “The Court has
often recognized that “in connection with” can bear a “broad interpretation.” Merrill Lynch,
Pierce, Fenner & Smith Inc. v. Dabit, 547 U.S. 71, 85, 126 S. Ct. 1503, 164 L. Ed. 2d 179
(2006) (interpreting “in connection with the purchase or sale” broadly in the context of § 10(b) of
the Securities Exchange Act of 1934, 15 U.S.C. § 78j(b)); see, e.g., United States v. American
Union Transport, Inc., 327 U.S. 437, 443, 66 S. Ct. 644, 90 L. Ed. 772 (1946) (describing the
phrase “in connection with” in the Shipping Act, 1916, 39 Stat. 728, as “broad and general”).
The Court has also recognized that “‘in connection with’ is essentially indeterminate because
connections, like relations, stop nowhere.” Maracich v. Spears, 570 U.S. 48, 59, 133 S. Ct.
2191, 186 L. Ed. 2d 275 (2013) (quotation altered).
In HQ H345037, CBP held that sports equipment, referee equipment, and broadcast
equipment were determined to be imported “in connection with” international athletic events.
Similarly, we find that OBS equipment, OMEGA timing and results equipment, and the boats
and sailing boards used in or to broadcast the Games will be imported “in connection with” the
Olympic and Paralympic Games.
Furthermore, in determining whether goods imported by LA 28, its participants, officials,
and other aforementioned organizations are imported “on behalf of the foregoing persons or the
organizing committee,” CBP has looked to agreements made with such people or organizations.
In New York Ruling Letter (“NY”) N261136, dated February 13, 2015, CBP addressed whether a
company importing bleacher equipment for a Formula One race in Austin could receive duty-free
treatment under subheading 9817.60.00, HTSUS. CBP stated, “[a]llowance for duty-free
treatment under 9817.60.00 should be granted, upon your client submitting satisfactory evidence
by means of a rental or lease agreement or a similar use agreement issued to an accredited
member (organizing committee) or authority, i.e., Circuit of the Americas [the venue], or the FIA
[the hosting committee], disclosing that the disassembled event seating will be used at the
Formula 1, United States, Grand Prix, at Austin.” See also HQ H345037. Therefore, to support
whether an organization is importing articles “on behalf of the foregoing persons or organizing
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committee,” an organization must be able to show some agreement with the foregoing persons or
organizing committee, such as LA 28 or the venues hosting the Olympic Games.
Based on the information you provided, we find that the OBS equipment, OMEGA
timing and results equipment, and boats and sailing boards fall within the coverage of
subheading 9817.60.00, HTSUS, and qualify for duty-free entry in that provision, provided that
none of the items is being offered for sale or distribution to the public, and provided that said
items are imported by, or on behalf, of eligible individuals or entities as discussed above.
We note however, that in accordance with U.S. Note 8, Subchapter XVII, Chapter 98:
“[a]ny article exempt from duty under heading 9817.60.00 shall be free of taxes and fees that
may otherwise be applicable, but shall not be free or otherwise exempt or excluded from routine
or other inspections as may be required by the Customs Service.”
Finally, LA 28 has also inquired as to whether donating goods for legacy purposes after
the event, including integration into venue infrastructure or distribution to non-profit
organizations and community programs, would be considered distribution and negate the duty-
free status available under subheading 9817.60.00, HTSUS. LA 28 states that LA 28 will include
provisions in agreements with donee organizations to ensure that donated items cannot be resold,
redistributed, or auctioned. We agree.
In NY N335930, dated November 1, 2003, CBP held that goods distributed to
participants, games officials, and volunteers could still fall under subheading 9817.60.00,
HTSUS, because they were not intended for distribution to the public. Therefore, there is
precedent for limited distribution to those directly related to the games being allowed under this
subheading. Further, in HQ H345037, CBP held that goods donated for legacy purposes to non-
profits, charities, and public entities would not negate duty-free status under subheading
9817.60.00, HTSUS, when provisions were included in agreements with donee organizations
ensuring the items could not be redistributed, resold, or auctioned. Therefore, LA 28’s intended
donations would not violate this provision of subheading 9817.60.00, HTSUS, as long as there
are assurances provided that the goods will not later be sold or distributed to the public.
HOLDING:
The OBS equipment, OMEGA timing and results equipment, and boats and sailing
boards related to the preparation, operation, and competition of the 2028 Olympic and
Paralympic Games at issue are eligible for duty-free treatment under subheading 9817.60.00,
HTSUS.
Please note that 19 C.F.R. § 177.9(b)(1) provides that “[e]ach ruling letter is issued on the
assumption that all of the information furnished in connection with the ruling request and
incorporated in the ruling letter, either directly, by reference, or by implication, is accurate and
complete in every material respect. The application of a ruling letter by a Customs Service field
office to the transaction to which it is purported to relate is subject to the verification of the facts
incorporated in the ruling letter, a comparison of the transaction described therein to the actual
transaction, and the satisfaction of any conditions on which the ruling was based.”
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A copy of this ruling letter should be attached to the entry documents filed at the time this
merchandise is entered. If the documents have been filed without a copy, this ruling should be
brought to the attention of the CBP officer handling the transaction.
Sincerely,
Yuliya A. Gulis, Director
Commercial and Trade Facilitation Division
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