OT:RR:CTF:VS H360670 AP
Matthew Mermigousis
BDO USA
201 Old Country Road
Melville, NY 11747
RE: Subheading 9817.60.00, HTSUS; Equipment and Goods Related to CONCACAF
Dear Mr. Mermigousis:
This is in response to your ruling request, dated December 19, 2025, on behalf of your
client, the Confederation of North, Central America and Caribbean Association Football
(“CONCACAF”), 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 imported by or on behalf of CONCACAF, shipped to and stored in the United States
for use in connection with its international athletic events held in the United States and other
countries from 2026 to 2030 and not intended for sale or distribution to the public.
The importer has asked that certain information submitted in connection with this ruling
be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R.
§ 177.2(b)(7), the request for confidentiality is approved. The information contained within
brackets in italics in this ruling or in the attachments to the ruling request, forwarded to our
office, will not be released to the public and will be withheld from published versions of this
ruling.
FACTS:
CONCACAF is one of International Federation of Association Football’s (“FIFA”) six
continental governing bodies, overseeing 41 member associations from North America, Central
America, the Caribbean, and three South American nations. CONCACAF’s primary role is to
organize and oversea competitions for national teams and clubs such as CONCACAF Gold Cup,
CONCACAF Nations League, CONCACAF Champions League, CONCACAF Champions Cup,
Women’s Gold Cup and Women’s Championship, CONCACAF Men’s and Women’s Beach
Soccer, CONCACAF Men’s and Women’s Futsal, and Youth Competitions. You have provided
a list of the international tournaments and activities that will take place in the United States and
other countries from 2026 to 2030. You explain that all goods and equipment supplied for these
CONCACAF events will be shipped by vendors to a third-party logistics warehouse in the
United States. Warehousing and distribution activities, including movement from the port to the
warehouse and subsequent deployment, will be managed by vendors or third parties acting on
behalf of CONCACAF. You state that the goods will remain dedicated to event use and will not
enter into general commerce. For the events held in the United States, goods will be distributed
directly from the warehouse to the event venues. For events organized in other countries, goods
will be imported and stored in the United States and will be subsequently shipped to the
destination country for use in the events.
The CONCACAF events include football matches and training sessions, ceremonies such
as opening, closing, and award presentations, seminars, meetings, conferences, workshops, press
conferences, public viewing opportunities and fan-related activities, and cultural components
(exhibitions, displays, shows). The CONCACAF events support social development initiatives,
humanitarian efforts, and charitable projects. Other activities include staging, organization,
marketing, promotion, and conclusion of competitions.
CONCACAF intends to import the following goods:
• Uniforms, balls, goal nets, trophies, awards, medals;
• Accreditation equipment used to manage control and access to events (pouches, lanyards,
credentials, wristbands);
• Protocol gifts used for ceremonial or diplomatic purposes provided by CONCACAF to
participants, officials, or sponsors in connection with the event (commemorative plaques,
trophies, crystal awards, framed memorabilia, coins, or similar recognition items).
• Sports equipment (banners, patches, armbands, flags, scarves, sub boards);
• Referee equipment (radios, video assistant referee equipment, whistles, stretchers);
• Team training equipment;
• Broadcast, audio, and media equipment;
• Special events/stage/venue equipment and tools;
• Pitch/field management equipment;
• Infrastructure equipment (stadium seating, food display racks, temporary infrastructure);
• Promotional materials;
• Technology equipment;
• Commercial affiliate and partner/sponsor goods (hats, t-shirts, lanyards, keychains,
reusable water bottles, sponsor giveaway items, and hospitality gifts distributed to invited
guests or participants).
• Personal items for CONCACAF client groups (individually distributed food and beverage
items, toiletries, personal care products, and similar consumable/personal-use items); and
• Anti-doping sample collection and equipment.
The vendors responsible for importation are entities based in the United States and
overseas (in [X], [X], [X], [X], and [X]). You have provided a list of the vendors. In most cases,
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CONCACAF’s vendors will deliver the goods on a Delivered Duty paid (“DDP”) basis and will
act as the importer of record.
The goods imported in connection with the CONCACAF events will be allocated for use
by staff, volunteers, referees, coaches, teams, and CONCACAF client groups. The goods will be
designated for use at stadiums for practice and match fields and by member associations for
development activities. All imported goods will be intended solely for use in relation to the
event and will not be for sale or distribution to the public.
In addition, CONCACAF may import surplus goods, such as infrastructure materials,
equipment, or operational supplies, into the United States that were not used during events held
in other countries. These goods may either be retained for future CONCACAF events or donated
to approved organizations. In some cases, goods may be routed through U.S. warehouses before
deployment or returned from event locations if not used. Such goods are not intended for
commercial sale or public distribution.
Post-event, certain goods and equipment may be donated to staff, volunteers, non-profit
organizations, local clubs, or other charity/public entities as part of CONCACAF’s legacy and
social development initiatives. All donated goods are intended strictly for charitable purposes,
and not for resale or public distribution. CONCACAF intends to include provisions with donee
organizations requiring that donated goods are not to be resold, redistributed, or auctioned, and
are used solely for designated legacy or community purposes. Where formal agreements are not
in place, CONCACAF will communicate these restrictions directly to the recipient organizations
and obtain acknowledgment of these conditions to ensure the goods are not distributed to the
public.
ISSUE:
Whether the various equipment and goods imported by or on behalf of CONCACAF,
shipped to and stored in the United States for use in connection with its international athletic
events held in the United States and other countries, and not intended for sale or distribution to
the public, 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,
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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”).
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 FIFA World Cup Soccer Games are specifically enumerated under subheading
9817.60.00, HTSUS, as eligible international athletic events. In Headquarters Ruling Letter
(“HQ”) H345037, dated April 9, 2025, U.S. Customs and Border Protection (“CBP”) determined
that FIFA Club World Cup 2025™ and the FIFA World Cup 26™ were specifically enumerated
in the statute. In New York Ruling Letter (“NY”) N273612, dated March 31, 2016, CBP held
that the 2016 Copa America held as part of an agreement between CONMEBOL and
CONCACAF met the criteria of an international athletic event. In NY N242515, dated June 21,
2013, CBP determined that the IZOD IndyCar Series held in the United States and abroad was a
race that qualified as an international athletic (sport) event under subheading 9817.60.00,
HTSUS. The CONCACAF events are similar in scope (i.e., Copa America organized by
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CONMEBOL and CONCACAF) and therefore, this requirement under subheading 9817.60.00,
HTSUS, is met.
Further, you state that the items will not be offered for sale or distribution to the public,
and as such constitute “articles not intended for sale or distribution to the public” for purposes of
subheading 9817.60.00, HTSUS.
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 . . .” In HQ H345037, supra, 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 for
• tournament/event use;
• Special events goods/stage equipment/venue equipment and 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 and equivalent for staging tournament and events;
• Catering equipment for staging tournament and events;
• Anti-doping samples collection and equipment to ensure compliance with
international regulations for the tournament;
• Medical equipment to be used by FIFA Client Groups for tournament use;
• Broadcast, audio, and 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 and 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.
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In NY N273612, supra, the following equipment was eligible under subheading
9817.60.00, HTSUS:
• Soccer goals, nets, balls, stadium seating, food for the team/family, display racks
• Audio/media equipment
• Uniforms/banners/pictures
• Furniture/Office equipment
• Promotional materials tied to the event
• Timing equipment
• Venue equipment and materials to run the event, such as whistles, stretchers
• Medical/Training materials such as bandages
• Sponsor’s goods, materials and equipment to run the event
• Team training materials, equipment, tools, uniforms or accessories that are
required for use or to be used to execute the games
• Hospitality items that assist an accredited member in displaying the culture of
their country, team, sport or bid for future hosting of the event
• Broadcasters and Media accredited parties’ material, equipment and goods needed
or used in conjunction with the event, and
• Personal items of the accredited family members
In HQ H035769, dated August 20, 2008, CBP concluded that clothing, gift sets (leather
and silver gifts, cufflinks in silver, porcelain chess set), office materials, luggage, golf bags and
umbrellas imported for use by the European Team of Ryder Cup Europe LLP (including
contestants, caddies, partners/spouses/family members and Ryder Cup LLP staff members) was
classifiable in heading 9817.60.00, HTSUS.
In NY N242515, supra, all equipment and goods related to the IZOD IndyCar Series
races to be held at specified racing circuits in the United States and in countries abroad were
imported and re-exported via Air Charter and Ocean Container, as well as various truck load
shipments in and out of Canada and Mexico. The goods included all the necessary equipment
for participation in the races held in the United States and abroad, not limited to, the racers’ gear;
the racing cars and engines; the wheels and tires for the cars; the tools for the upkeep and repairs
of the vehicles, as well as support equipment, such as television broadcasting equipment, team
tents, and comforts.
Furthermore, in determining whether goods imported by various vendors on behalf of
CONCACAF are imported “on behalf of the foregoing persons or the organizing committee,”
CBP has looked to agreements made with such people or organizations. See HQ 345037, supra
and HQ H359026, dated June 10, 2026 (noting that “to support whether an organization is
importing articles ‘on behalf of the foregoing persons or organizing committee,’ an organization
must be able to show some agreement with the foregoing persons or organizing committee,”
such as FIFA or the venues hosting the World Cups). You state that CONCACAF maintains
formal agreements with companies and vendors who import the merchandise for the events.
Warehousing and distribution activities, including movement from the port to the warehouse and
subsequent deployment, will be managed by vendors or third parties acting on behalf of
CONCACAF. You state that the goods stored in a third-party logistics warehouse in the United
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States will remain dedicated to event use and will not enter into general commerce. For the
events held in the United States, goods will be distributed directly from the warehouse to the
event venues. For events organized in other countries, goods will be imported and stored in the
United States and will be subsequently shipped to the destination country for use in the events.
Therefore, based on the submitted information, we find that the enumerated merchandise
imported by or on behalf of CONCACAF, shipped to and stored in the United States for use in
connection with its international athletic events held in the United States and other countries, and
not intended for sale or distribution to the public falls within the coverage of subheading
9817.60.00, HTSUS, and qualifies 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. Please note 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.”
Lastly, you advise that CONCACAF intends to include provisions with donee
organizations requiring that donated surplus and non-surplus goods are not to be resold,
redistributed, or auctioned, and are used solely for designated legacy or community purposes.
You also state that where formal agreements are not in place, CONCACAF will communicate
these restrictions directly to the recipient organizations and obtain acknowledgment of these
conditions to ensure the goods are not distributed to the public and remain consistent with the
requirements of subheading 9817.60.00, HTSUS. Donating surplus and non-surplus goods and
equipment as part of CONCACAF’s legacy and social development initiatives strictly for
charitable purposes and not for resale or public distribution after the events could still fall under
subheading 9817.60.00, HTSUS, as long as the goods are used solely for the designated legacy
or community purposes and are not for resale or public distribution. See HQ H359026, supra
(stating that donations would not violate the provisions of subheading 9817.60.00, HTSUS as
long as there are assurances that the goods will not later be sold or distributed to the public).
HOLDING:
The subject equipment and goods imported by or on behalf of CONCACAF, shipped to
and stored in the United States for use in connection with its international athletic events held in
the United States and other countries from 2026 to 2030, and not intended for sale or distribution
to the public 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 [CBP] 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,
Monika R. Brenner, Chief
Valuation and Special Programs Branch
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