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

Maya Kessler
Costco Wholesale
999 Lake Dr.
Issaquah, WA 98027

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

Dear Ms. Kessler:

In your letter dated May 24, 2019 you requested a tariff classification ruling.

The merchandise under consideration is identified as the Touch and Learn Activity Desk (Activity Desk), Item #1315625. The Activity Desk is described as an interactive learning device intended for children between the ages of two and five years old. The Activity Desk consists of an interactive desktop with a replica phone, music player, LED display, activity card slot, and activity page area. The desktop can be turned over to reveal a chalkboard easel and art station. You state that the Activity Desk comes with five interactive pages that can be inserted into the activity card slot on the desktop. The activity pages display visual icons that correspond to separate activities to include counting, playing music, reciting the alphabet, and association of the human body and food. Once inserted, the icons become active buttons that, when depressed, play a corresponding audio cue. You also state that expansion packs can be purchased to add additional subjects as the child advances.

The applicable subheading for the Touch and Learn Activity Desk, Item #1315625 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