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

Sharon Tuck
Dollar General
100 Mission Ridge
Goodlettsville, TN 37072

RE: The tariff classification of learning watches from China

Dear Ms. Tuck:

In your letter dated March 9, 2022, you requested a tariff classification ruling.

There are two items at issue with this request described as learning watches. The first is the Vtech Paw Patrol Learning Watch, which is a child’s wristwatch decorated with designs depicting various characters and themes from the Paw Patrol children’s television show. The watch incorporates multiple interactive learning games centered around the characters from the show. These include pattern recognition lessons as well as games involving math principles. Additionally, the watch displays a digital output of the time and incorporates a stopwatch, alarm, and timer function, which you state allow the child to further learn the concepts of telling time.

The second item is identified as the Leapfrog Blue’s Clues Learning Watch, which is a child’s wristwatch decorated with designs depicting various characters and themes from the Blue’s Clues children’s television show. The watch incorporates multiple interactive games centered around the characters of the show and meant to teach and reinforce skills such as counting, pattern recognition, and shapes. Additionally, the watch displays a digital output of the time and incorporates a stopwatch, alarm, and timer function, which you state allow the child to further learn the concepts of telling time.

In your request, you suggest that the subject learning watches are accurately classified within subheading 8543.70.9301, Harmonized Tariff Schedule of the United States (HTSUS). We agree.

The applicable subheading for the Vtech Paw Patrol and Leapfrog Blue’s Clues Learning Watches will be 8543.70.9301, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified 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.

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