CLA-2-96:OT:RR:NC:N4 462
Kate Eckhoff
Geodis
5101 S. Broad Street Philadelphia, PA 19112
RE: The tariff classification of a nail art tool from China
Dear Ms. Eckhoff:
In your letter dated January 14, 2025, you requested a tariff classification ruling. Photos and product descriptions were provided for our review.
The item under consideration is the “Nailed it!” nail art tool. It is a manual hand tool with interchangeable heads, that when not in use, are stacked together to form the handle of the tool. There are four heads in total: two nylon brush heads, one for striping and one for detailing, and two metal tool heads, one for dotting, and one for manipulating gemstones. The tool’s intended use is for creating handmade artwork upon nails, both real and artificial.
The Explanatory Notes (ENs) to the Harmonized Tariff Schedule of the United States (HTSUS) constitute the official interpretation of the tariff at the international level. EN XII to General Rule of Interpretation (GRI) 3(c) provides in part: “when goods cannot be classified by reference to Rule 3(a) specific description or 3(b) essential character, they are to be classified in the heading which occurs last in numerical order among those which equally merit consideration in determining their classification.” In this case, the nail brush heads would be classified under heading 9603, which occurs last in numerical order in comparison to the other components, GRI 3(c) noted.
In your request, you suggest that the subject item is correctly classified under subheading 9603.30.6000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the “Nailed it!” nail art tool will be 9603.30.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): artists' brushes, writing brushes and similar brushes for the application of cosmetics: valued over 10¢ each.” The general rate of duty is 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Sandra Sary at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division