CLA-2-95:OT:RR:NC:N4:424
Mr. Gavin Roberts
Trade Flow Customs Consultancy Ltd
129 Western Road, Hurstpierpoint
Hassocks, BN69SY
United Kingdom
RE: The tariff classification of jigsaw puzzle accessories from China
Dear Mr. Roberts:
In your letter submitted April 3, 2020, you requested a tariff classification ruling on behalf of your client, Galt Toys Inc.
Photographs and descriptive literature referencing four types of jigsaw puzzle accessories in the Porta Puzzle product line were received with your inquiry. Each Porta Puzzle item is basically a contrivance in which one may assemble and or store a partially worked jigsaw puzzle. The Porta Puzzle products are solely for use with jigsaw puzzles to provide a working surface for jigsaw puzzles (not included). Upon partial completion a puzzle may be stored securely and safely for future use, leaving the partially assembled jigsaw puzzle intact. According to the information provided with your request, the products do not specify a particular age designation, however, you state that the products are intended for use by individuals twelve years of age and over.
The Porta Puzzle Standard 500 –1000 piece, item 10715, is described as a jigsaw puzzle board with fold over sides that when fastened with the velcro closure, provide protective storage for an incomplete jigsaw puzzle. The outer surface of the puzzle board work surface has a polyester PVC coating. The interior surface of the puzzle board is covered in flocking material to prevent the puzzle pieces from sliding, and provides a work surface that can accommodate up to a 1000 piece jigsaw puzzle. Also included are two additional covered boards that may be used to sort and spread out the puzzle pieces while working the puzzle. For storage, the additional boards can be placed atop the partially assembled puzzle on the puzzle board, then all sides of the puzzle board surface are folded over and secured with the velcro closure. The partially completed jigsaw puzzles can then be moved and stored for future use without disrupting efforts to complete the jigsaw puzzle.
The Porta Puzzle Standard 500 –1500 piece, item10806, is nearly identical in design, function and construction to item 10715. It’s slightly larger size allows for the work surface to accommodate and store up to a 1500 piece jigsaw puzzle.
The Porta Puzzle Deluxe 500-1000 piece, item 01039 is also nearly identical in design and function to the Porta Puzzle Standard products described above. The construction of this model differs in that this product features a zip closure with a carry handle and the exterior surface of the puzzle board work surface is covered in PVC leather material.
The Porta Puzzle Board, item 17957, consists only of a puzzle board work surface covered in flocking material. It is intended that one will spread out puzzle pieces on the board and use it as a working surface for a jigsaw puzzle. In various stages of completion, the jigsaw puzzle may be put away or moved to another location until the user is ready to resume, however this board must remain flat to ensure the puzzle remains intact.
The aforementioned Porta Puzzle products meet the definition as accessories to puzzles, as they are principally designed to be used with jigsaw puzzles and contribute to the effectiveness in preserving partially completed puzzles by providing a portable work surface and the convenient storage of puzzles. Therefore, the products are classifiable as accessories to puzzles.
The applicable subheading for the Porta Puzzle items 10715, item 10806, item 01039 , and item 17957 will be 9503.00.0090, HTSUS, which provides for “Tricycles, scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof…Other.” The rate of duty will be Free.
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 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 Roseanne Murphy at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division