CLA-2-90:OT:RR:NC:N3:135

Ms. Natasha Frykman
Spoonk Space Inc.
164 Bay Lynn Drive Unit F
Lynden, WA 98264

RE: The tariff classification of a massage roller from China

Dear Ms. Frykman:

In your letter dated January 25, 2019, you requested a tariff classification ruling of a Spoonk mat and a massage roller. Representative samples were not included with your request; however, you provided a picture and video and referenced your website for additional information.

The massage roller is identified on your website as a Spoonk magnetic roller. The hand-held mechanical massager has peanut-shaped massage balls on a metal bar with rubber handles on each end. Each ball has two rows of protruding rubber nodules. The product is rolled against the user’s body to create a massaging effect. According to your website, the massage roller with added magnetic therapy effect is “engineered to match contours of the back.” It is equipped with internal ball bearings, massage nodules, magnetic technology and non-slip handles.

The first item in your request, the Spoonk mat, has already been ruled upon in Headquarters ruling HQ H266056, dated January 16, 2018. In HQ H266056, the product under consideration was described as an "acupressure massage mat encasement.” We are unsure if the article that is subject to this request is identical or would include the mentioned foam inserts. Based on the law and analysis provided within this HQ ruling, the classification would be unchanged whether these are the complete mats or the ruled upon encasements. Please note, the classification provided, 3926.90.9980, HTSUS, has been modified and is currently 3926.90.9990, HTSUS.

The applicable subheading for the massage roller will be 9019.10.2050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Mechano-therapy appliances and massage apparatus …Massage apparatus: Other.” 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 athe Spoonk mat contact National Import Specialist Kristopher Burton at [email protected]. If you have any questions regarding the massage roller contact National Import Specialist Fei Chen at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division