CLA-2-85:OT:RR:NC:N2:212

Terry Bush
Excite USA
4393 Sunbelt Dr.
Addison, TX 75001

RE: The tariff classification of an interactive learning device from China

Dear Ms. Bush:

In your letter dated May 8, 2019 you requested a tariff classification ruling.

The merchandise under consideration is identified as the Winfun Tiny Tots Learning Pad, Item # 9046291 and you submitted a sample for review. The item is described as an interactive learning device intended to be used by children ages 24 months and up. The item consists of a plastic pad with buttons depicting the alphabet, numbers one through ten, animals and music notes. Each button has a corresponding audio cue that is played through the incorporated speaker when depressed. These include repeating the letter or number, making animal sounds, and playing the alphabet song. The learning pad is designed to teach young children letter and number identification, animal recognition as well as the ABC song in a fun and interactive way.

The applicable subheading for the Winfun Tiny Tots Learning Pad will be 8543.70.9301, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Portable interactive electronic education devices primarily designed for children”. The general rate of duty will be free.

The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods to an applicable Chapter 99 subheading and whether additional tariffs may apply to certain products of China. 

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 on the World Wide Web at https://hts.usitc.gov/current.

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, contact National Import Specialist Luke LePage at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division