CLA-2-42:OT:RR:NC:N4: 441
Renee Esquer
Mattel, Inc.
333 Continental Blvd.
El Segundo, CA 90245
RE: The tariff classification of a child’s backpack and toys from China
Dear Ms. Esquer:
In your letter dated April 8, 2025, you requested a tariff classification ruling. You have submitted
photographs and descriptive literature for our review.
The article at issue, SKU: JLB86, consists of a child’s backpack and toys (a polypropylene granola bar, a
silicone popper with carabiner, three felt bandages, a polypropylene carrying case, non-functional
polypropylene walkie talkie, and water bottle made of ABS and polypropylene.) The child’s backpack is
made of 100 percent polyester, which is a man-made textile material. The backpack is designed to provide
storage, protection, organization, and portability to the child’s personal effects during travel. It features one
main compartment with a bear face flap. It secures with hook-and-loop fasteners. The front features one
pocket. The back of the pack has two straps that allow the child to wear it over the shoulders on the back. It
measures approximately 8 inches (H) x 5 inches (W) x 3 (D) inches.
While the backpack and toy products are packaged and sold together, the items are not considered a set for
tariff purposes as they do not meet the requirements of a General Rule of Interpretation (GRI) 3(b). The
contents are camping supplies that are not dedicated to a specific activity. Therefore, the backpack and toy
products will be classified separately.
The applicable subheading for the backpack will be 4202.92.3120, Harmonized Tariff Schedule of the United
States (HTSUS), which provides for travel, sports, and similar bags, with outer surface of textile materials, of
man-made fibers, backpacks. The general rate of duty will be 17.6 percent ad valorem.
The applicable subheading for the toy products will be 9503.00.0071, HTSUS, which provides for “Tricycles,
scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories
thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as
intended for use by persons: Under 3 years of age.” The general rate of duty will be Free.
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 subheadings 4202.92.3120 and 9503.00.0071, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63, in addition to
subheading 4202.92.3120 and 9503.00.0071, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 4202.92.3120, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 4202.92.3120, 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.
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 Vikki Lazaro at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division