CLA-2-95:OT:RR:NC:N3:356
Ryan Lickfeld
Geodis USA LLC
5101 South Broad Street
Philadelphia, PA 19112
RE: The tariff classification of the “Dino Carry Case Play Set” from China
Dear Mr. Lickfeld:
In your letter submitted on June 26, 2025, you requested a tariff classification ruling on behalf of your client,
CVS Pharmacy, Inc.
Photographs and a description of the “Dino Carry Case Play Set” were submitted with your inquiry.
The article under consideration, CVS Pharmacy item number 261648, is a play kit. The plastic carrying case
is a toy in the shape of a dinosaur with posable arms and mouth. It is 10.5 inches high by 22 inches wide and
has a depth of 4.3 inches. The case features storage compartments that hold eight toy vehicles and four
smaller dinosaur figures. Children will derive amusement by using the contents of the set to create their own
dinosaur and car displays. The kit is principally designed for the amusement of children ages 3 and older.
In your request, you suggest classification of this product as a toy in subheading 9503.00.0073, Harmonized
Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the " Dino Carry Case Play Set,” item number 261648, will be 9503.00.0073,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Tricycles, scooters, pedal
cars, and similar wheeled toys… dolls, other toys… puzzles of all kinds; parts and accessories thereof…
‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended
for use by persons: 3 to 12 years of age.” The rate of duty will be Free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 9503.00.0073, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
9503.00.0073, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9503.00.0073, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 9503.00.0073, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 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, please contact
National Import Specialist Maryalice Nowak at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division