Ms. Sheila Goodrich
M-PACT Solutions LLC
4294 Swinnea Road
Memphis, TN 38118

RE: The tariff classification of a “Room Defender Kit” from China

Dear Ms. Goodrich:

In your letter, dated March 11, 2019, you requested a tariff classification ruling on behalf of your client, Scholastic Inc. A product description and photos were submitted for our review.

The “Room Defender Kit” is a 31 page illustrated book designed for children and packaged together with an audio amplifier circuit. The book provides children instructions on how to protect their room (for example, by building a room alarm using the audio component), make and break codes, hide possessions (for example, by creating a hidden drawer), make a spy scope, investigate suspects (for example, by taking fingerprints in cocoa powder), etc. The audio amplifier circuit consists of two LR41 batteries and a circuit board with wires connecting to the speaker. It is packaged in an envelope-like flap attached to the back inner cover of the book. Because the “Room Defender Kit” (a) consists of at least two different articles which are, prima facie, classifiable in different headings; (b) consists of products or articles put together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without repacking, the kit will be considered a set for customs purposes. Sets are classified according to the component, or components taken together, which can be regarded as conferring on the set as a whole its essential character. In this case, the instruction book confers the essential character.

The applicable subheading for the “Room Defender Kit” will be 4901.99.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Technical, scientific and professional books.” 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 the World Wide Web at

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 Charlene Miller at [email protected].


Steven A. Mack
National Commodity Specialist Division