CLA-2-39:OT:RR:NC:N4:415
Sally Gifforrd Geodis USA 5101 South Broad Street Philadelphia, PA 19112 RE: The tariff classification of a beaded bag charm from China. Dear Ms. Gifford: In your letter dated February 26, 2025, you requested a tariff classification ruling on behalf of your client, Primark US. An image was provided in lieu of a sample. The product under consideration is described as a four-inch-long bag charm, style number 991138753. It is intended to be attached to a bag strap by its metal clip. It features four decorations attached to the clip: a twisted polyester cord, two strands of plastic beads, and a flat polyester textile charm that is completely covered on the surface by glass and plastic beads and has the appearance of an avocado sliced in half. We reviewed the cited New York ruling L87972, dated October 17, 2005, and agree this charm is similar enough that it would be classified in the same manner. The applicable subheading for the bag charm, style number 991138753, will be 3926.90.3500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [b]eads, bugles and spangles, not strung (except temporarily) and not set; articles thereof, not elsewhere specified or included: [o]ther.” The column one, general rate of duty is 6.5 percent ad valorem. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 3926.90.3500, HTSUS, unless specifically excluded, are subject to an additional 15 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 3926.90.3500, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 3926.90.9989, HTSUS, listed above. 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/current. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division