CLA-2-84:OT:RR:NC:N1:104
Natasha Lawrence
Tokyo Grab HI LLC
95-1043 Kaapeha St APT 244
Mililani, HI 96789
RE: The tariff classification of a claw type vending machine from China
Dear Ms. Lawrence:
In your letter dated April 15, 2025, you requested a tariff classification ruling.
The product in question is a claw type arcade vending machine into which prize items such as small plush
toys or novelty articles will be placed. You note that the prize items will not be imported with the machine.
The unit measures approximately 800mm (W) x 838mm (D) x 1905mm (H) and weighs 102.5 kg. The
machine will not dispense food or beverages.
Your submission indicates that the claw machine incorporates a coin-operated payment mechanism. Placing a
coin into this mechanism allows the player to manipulate an internal mechanical claw using a joystick device
to try and grab a prize item. If the player is successful, the claw will grab and lift a prize item and deposit it
into a chute, where it will drop to the bottom of the machine and be dispensed to the player through a round
opening.
You suggest classification under subheading 9504.30.0020, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Video game consoles and machines, table or parlor games, including pinball
machines, billiards, special tables for casino games and automatic bowling equipment, amusement machines
operated by coins, banknotes, bank cards, tokens or by any other means of payment: [O]ther games, operated
by coins, banknotes, bank cards, tokens or by any other means of payment, other than automatic bowling
alley equipment; parts and accessories thereof [P]inball machines and bell-type machines and consoles.”
However, as the claw machine automatically dispenses products in exchange for payment made at the
machine, it meets the general criteria for vending machines of heading 8476, HTSUS. Accordingly, the claw
machine is not classifiable in heading 9504.
The applicable subheading for the claw type vending machine will be 8476.89.0000, HTSUS, which provides
for Automatic goods-vending machines (for example, postage stamp, cigarette, food or beverage machines),
including money-changing machines; parts thereof: Other machines: Other. 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 subheading 8476.89.0000, 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 8476.89.0000, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8476.89.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 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 8476.89.0000, 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/programs-administration/trade-remedies, 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 Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division