Ms. Elizabeth Morris
Rogers and Brown CHB
2 Cumberland Street
P.O. Box 20160
Charleston, SC 29413

RE: The tariff classification of a soft fabric book sewing kit from China

Dear Ms. Morris:

In your letter, dated March 11, 2019, you requested a tariff classification ruling on behalf of your client, Fabric Editions Inc. A sample of the PC-LW-Bunnybook was submitted for our review and will be returned, per your request.

The PC-LW-Bunnybook is a kit containing the necessary elements to sew your own soft fabric book entitled, “Some Bunny Loves You.” Included are a sheet of printed 100% cotton fabric, measuring 36” by 42”, and a piece of white polyester fleece batting, measuring 25” by 40”. Printed on the cotton fabric are 12 book pages and instructions for kit assembly. The book page panels depict large color illustrations of a mother bunny and her baby with accompanying text. The consumer is instructed to cut out each page set (two connected pages) and a correspondingly sized piece of batting and sew them together using a sewing machine and thread (not supplied). The finished product is a children’s book made of quilted fabric. Because the Bunnybook 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 (creating a fabric book); 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 panel of cotton fabric bearing the instructions and uncut book pages confers the essential character.

The applicable subheading for the PC-LW-Bunnybook fabric book kit will be 4911.91.1500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other printed matter, including printed pictures and photographs: Pictures, designs and photographs: Printed not over 20 years at the time of importation: Suitable for use in the production of articles of heading 4901.” 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